BLST Northstar, LLC v. Santander Consumer USA, Inc.

Background

The court considered the parties’ joint motion to continue sealing documents filed in connection with their agreement allowing the plaintiffs to file an amended complaint. The sealed materials included two exhibits and the amended complaint. Redacted versions of each document were filed publicly.

The plaintiffs argued that the documents contained contract terms covered by confidentiality provisions. They said confidentiality obligations were owed to the parties and to a third contracting entity that was not involved in the lawsuit. Santander Consumer USA, Inc. took no position on continued sealing. The court had previously allowed the original complaint to remain sealed for similar reasons.

Legal standard

Under the District of Minnesota’s local rules, parties may seal civil-case documents only under a statute or rule, or with the court’s permission. Judicial records generally carry a common-law presumption of public access, but that presumption is not absolute. The court must balance public access against legitimate interests in protecting confidential information. The weight given to public access depends partly on how important the material is to the exercise of the court’s constitutional decision-making authority.

Court’s analysis

The court reviewed the two exhibits and concluded they were unlikely to play a role in the district judge’s exercise of constitutional judicial power. Because the exhibits concerned a pretrial, non-dispositive matter, the court applied a lower level of public-access scrutiny. It found that each exhibit contained contract terms subject to confidentiality provisions and that the parties and a nonparty contracting entity had legitimate interests in preventing disclosure.

The court separately reviewed the sealed portions of the amended complaint. Although the amended complaint might eventually play a role in the district judge’s work, the court found good cause to maintain the sealing at that stage. It determined that the complaint contained confidential contract terms, that the redactions were sufficiently limited, and that the confidentiality interests outweighed the public interest in disclosure.

Disposition

Judge Dulce J. Foster granted the parties’ Joint Motion Regarding Continued Sealing. The clerk was directed to keep ECF Nos. 64, 64-1, and 68 under seal. The order did not decide the underlying claims in the lawsuit.