Mell v. Minnesota State Agricultural Society, The
- Eric Tostrud
- 0:21-cv-01040
- U.S. District Court · District of Minnesota
- 3
In Mell v. Minnesota State Agricultural Society, Judge Wright granted in part and denied in part a joint motion about sealing court documents.
Josianne Mell and the Minnesota State Agricultural Society, as well as members of the public seeking access to the listed court documents.
What happened
Mell v. Minnesota State Agricultural Society concerned whether certain court documents should remain hidden from public view. The parties jointly asked the court to continue sealing documents filed with a motion to amend the complaint.
The court ordered several documents unsealed, including Docket Entry 57 and the other entries the parties had agreed could be made public. It allowed other documents to remain sealed because they contained confidential health or financial information, Social Security numbers, or dates of birth.
Judge Elizabeth Cowan Wright granted in part and denied in part the joint motion. She denied the request as to Docket Entry 57 because labeling emails confidential under a protective order was not enough, by itself, to justify continued sealing; the parties could file a proper motion to seal that entry.
The detailed version
- Mell v. Minnesota State Agricultural Society, The · No. 0:21-cv-01040
- Eric Tostrud
- Sept. 27, 2022
Background
The parties filed a joint motion under Local Rule 5.6(d) asking the court to decide which documents filed under seal should remain sealed. The documents had been filed in connection with Josianne Mell’s motion to amend the complaint to reintroduce previously dismissed claims without prejudice.
The parties agreed that Docket Entries 60, 63, 64, 65, 74-2, 74-3, 74-6, 74-7, 74-9, 74-16, 74-17, 74-18, 74-20, 74-22, 74-23, 74-24, 74-25, 74-26, and 74-28 should be unsealed. They agreed that Docket Entries 52, 54, 55, 56, 58, 59, 61, 62, 66, 67, 74, 74-1, 74-4, 74-5, 74-8, 74-10, 74-11, 74-12, 74-13, 74-14, 74-15, 74-19, 74-21, and 74-27 should remain sealed because they allegedly contained confidential health information, financial information, Social Security numbers, and dates of birth.
Court’s analysis
The court concluded that the need to protect the information in the latter group outweighed the public’s right to access it. The court emphasized, however, that this decision concerned documents filed with non-dispositive motions and did not decide whether the information would remain sealed if later filed and considered in connection with dispositive motions, such as motions seeking judgment that would resolve claims. The court also expected the parties to meet and try to resolve any future disagreement about sealing before filing another joint motion.
Docket Entry 57 was different. The only stated basis for continued sealing was that the emails had been marked confidential by the defendant under a protective order. The court held that a confidentiality designation under a protective order, without more information, was not a sufficient basis for indefinite sealing under Local Rule 5.6(d). The court therefore could not grant continued sealing for that entry on the existing record.
Ruling
The court granted in part and denied in part the parties’ Joint Motion Regarding Continuing Sealing (Docket Entry 81). It ordered Docket Entries 57, 60, 63, 64, 65, 74-2, 74-3, 74-6, 74-7, 74-9, 74-16, 74-17, 74-18, 74-20, 74-22, 74-23, 74-24, 74-25, 74-26, and 74-28 unsealed in accordance with the Local Rules. It ordered the other listed entries to remain sealed and denied the motion as to Docket Entry 57. The court stated that the parties could file an appropriate motion if they wished to seek sealing of Docket Entry 57.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.