Sleep Number Corporation v. Young
- Nancy Brasel
- 0:20-cv-01507
- U.S. District Court · District of Minnesota
- 5
In Sleep Number v. Young, Judge Wright denied continued sealing without prejudice, unsealed one entry, and kept two others sealed.
Sleep Number Corporation, defendants Steven Jay Young, Carl Hewitt, and UDP Labs, Inc., and members of the public seeking access to the court records.
What happened
In Sleep Number Corporation v. Young, the parties jointly asked the District of Minnesota to keep numerous documents sealed. They relied mainly on protective-order confidentiality and claims that some materials were privileged.
The court said confidentiality labels alone were not enough because judicial records generally are open to the public. It denied continued sealing without prejudice for most listed entries but temporarily kept them sealed while allowing a renewed motion. It also ordered one entry unsealed and kept two entries sealed because they concerned claimed trade secrets and settlement communications.
Judge Elizabeth Cowan Wright issued the order. The parties had until January 3, 2022, to file a renewed joint motion explaining why the remaining documents should stay confidential; otherwise, the temporarily sealed entries would be unsealed.
The detailed version
- Sleep Number Corporation v. Young · No. 0:20-cv-01507
- Nancy Brasel
- Dec. 6, 2021
Background
The court considered the parties’ joint motions regarding continued sealing under District of Minnesota Local Rule 5.6(d). The motions concerned documents filed in connection with Sleep Number’s motions to compel and for sanctions under Federal Rule of Civil Procedure 37.
The parties agreed, or did not object, to continued sealing of numerous docket entries because the documents had been designated as protected under a protective order or contained material asserted to be privileged. The court explained that a protective-order designation alone does not justify keeping court records sealed indefinitely. The court therefore had to weigh the parties’ need for confidentiality against the public’s common-law right to inspect judicial records.
Rulings
The court denied without prejudice the joint motions as to the numerous entries listed in paragraph 1 of the order, including entries from Dockets 208, 213, 217, 220, 229, and 241 and their specified attachments. The entries were to remain temporarily sealed while the parties had an opportunity to file a renewed joint motion giving the court enough information to decide whether confidentiality outweighed public access. If no renewed motion was filed by January 3, 2022, the entries would be ordered unsealed under Local Rule 5.6(d).
The court denied in part the joint motions as to Docket Entry 229-3 and ordered that entry unsealed because it concerned discovery disputes and contained no confidential or privileged information.
The court granted in part the joint motions as to Docket Entries 229-6 and 235. Entry 229-6 was to remain under seal because it described in detail the trade secrets that Sleep Number claimed had been misappropriated. Entry 235 was to remain under seal because it contained confidential settlement communications, and the public’s interest in those negotiations did not outweigh the parties’ interest in confidentiality.
Effect of the Order
This was a sealing and public-access ruling, not a decision on the underlying claims or on the motions to compel and for sanctions. Most of the challenged entries remained temporarily sealed pending further action, one entry was to be unsealed, and two entries remained sealed under the court’s stated reasons.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.