Snyder v. UnitedHealth Group, Inc.
- John Tunheim
- 0:21-cv-01049
- U.S. District Court · District of Minnesota
- 10
In Snyder v. UnitedHealth Group, Judge Foster ordered some filings unsealed after 28 days and kept others sealed because the court had not relied on them.
The parties and the public were affected: some court filings were scheduled to become publicly accessible, while the remaining listed filings were kept under seal. The Clerk of Court was directed to carry out both parts of the order.
What happened
In Snyder v. UnitedHealth Group, Inc., the parties asked the court to decide which documents filed with an earlier motion should remain confidential. They agreed that some documents could be unsealed, but disagreed about others.
The court said the public generally has a right to access court records, but that right must be balanced against legitimate confidentiality interests. Because the district court had not relied on the disputed documents when deciding the earlier motion, the public’s interest in seeing them was weaker, and the defendants’ confidentiality interests outweighed it.
Judge Dulce J. Foster ordered the Clerk to unseal the agreed documents after 28 days unless a timely request for further consideration was filed. She ordered the Clerk to keep the remaining disputed documents sealed because redacting them to disclose only public information was impracticable.
The detailed version
- Snyder v. UnitedHealth Group, Inc. · No. 0:21-cv-01049
- John Tunheim
- Nov. 2, 2022
Background
The parties filed a joint motion concerning continued sealing of documents submitted in connection with defendants’ motion to dismiss the complaint or, alternatively, for summary judgment. Magistrate Judge Thorson had previously deferred a ruling on some documents because defendants had not adequately explained why the documents needed to remain sealed in their entirety or why redaction was impracticable. The parties later filed a supplement with more detailed explanations.
The opinion notes that the district court had denied defendants’ motion to dismiss and had summarily denied their summary-judgment motion as premature because discovery had not begun. The district court relied on the allegations in the complaint when considering the motion to dismiss, did not cite the disputed documents, and did not address the merits of the summary-judgment motion.
Sealing standard
The court explained that court records are generally subject to a common-law right of public access. That right is not absolute. The court must weigh the public’s interest in access against the interests supporting confidentiality, giving greater or lesser weight to access depending on how important the records were to the court’s exercise of its judicial power.
Because the district court did not rely on the disputed documents, the court found that the public’s interest in accessing them was weaker. The defendants provided countervailing reasons for confidentiality, and those reasons outweighed the public’s interest at this stage of the case. The court also found that it was impracticable to edit and redact the documents to disclose only publicly available information.
Ruling
The court directed the Clerk to unseal the following documents 28 days after the order was issued unless a timely motion for further consideration was filed: Documents 45-18, 45-19, 45-21 through 45-28, 59-1 through 59-12, and 60-2.
The court directed the Clerk to keep the following documents under seal: Documents 45-1 through 45-17, 45-20, 45-29 through 45-53, 60-1, 61, 61-1 through 61-11, and 70-1 through 70-22. The order concerned access to these filings and did not decide the underlying claims or the merits of the earlier summary-judgment motion.
Read the full 10-page opinion on CourtListener, the free public archive maintained by the Free Law Project.