Evanston Insurance Company v. Rembrandt Enterprises, Inc.
- Patrick Schiltz
- 0:22-cv-01540
- U.S. District Court · District of Minnesota
- 2
In Evanston Insurance v. Rembrandt Enterprises, Judge Foster granted continued sealing because the documents contained proprietary and biosecurity-sensitive information.
Evanston Insurance Company and Rembrandt Enterprises, Inc.; the specified court filings remain unavailable to the public under seal.
What happened
Evanston Insurance Company and Rembrandt Enterprises asked the court to keep certain filings related to Evanston’s summary-judgment motion under seal. The filings included Evanston’s exhibits and sealed portions of both parties’ written arguments.
The court recognized the public’s right to access judicial records but said that right must be balanced against legitimate confidentiality interests. After reviewing the materials, the court found that they contained proprietary information and information that could jeopardize biosecurity if made public.
Judge Foster ruled that the confidentiality interests outweighed the public interest in unsealing the materials. The court granted the parties’ joint motion for continued sealing and directed the clerk to keep the listed filings under seal.
The detailed version
- Evanston Insurance Company v. Rembrandt Enterprises, Inc. · No. 0:22-cv-01540
- Patrick Schiltz
- Oct. 11, 2023
Background
The court considered the parties’ joint motion to continue sealing documents filed in connection with Evanston Insurance Company’s Phase I motion for summary judgment. Evanston filed its supporting memorandum and five exhibits under seal, while also filing a publicly available redacted version of its memorandum. Rembrandt Enterprises filed its response under seal and a redacted version publicly.
The parties agreed that Evanston’s exhibits and the redacted portions of both parties’ memoranda should remain sealed because they contained proprietary, non-public information or information that could jeopardize biosecurity. The court’s order specifically addressed filings identified by their docket numbers.
Legal Standard
The court explained that civil-case documents may be sealed only under a statute or rule, or with the court’s permission. It also recognized a common-law right of public access to judicial records. That right is not absolute, however, and the court must balance public access against legitimate interests in confidentiality. The weight given to public access depends on the material’s role in the exercise of federal judicial power and its value to people monitoring the federal courts.
Court’s Analysis
The documents were filed in connection with a summary-judgment motion and could ultimately play a role in the district judge’s exercise of federal judicial power. Nevertheless, after reviewing the sealed portions, the court found good cause to keep them confidential. It determined that the materials contained proprietary information, including information that could jeopardize biosecurity if disclosed publicly. The court concluded that the parties’ legitimate confidentiality interests outweighed the public interest in unsealing the materials.
Disposition
The court granted the parties’ Joint Motion for Continued Sealing. It directed the clerk to keep ECF Nos. 57, 59, 59-1, 59-2, 59-3, 59-4, and 66 under seal.
The opinion is signed by Dulce J. Foster, United States Magistrate Judge.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.