Kahsai v. Dejoy

Background

Bereket Kahsai brought an employment-discrimination case against Louis DeJoy, the United States Postmaster General. The court had previously dismissed some claims and later granted DeJoy’s motion for summary judgment on the remaining claims because they were untimely and no tolling doctrine applied. Kahsai appealed the summary-judgment order to the Eighth Circuit.

After filing the appeal, Kahsai filed two motions asking the district court to unseal court documents. He described the requested materials as including audio, video, and text files, as well as reports and other documents that he said concerned his performance report, a personal health experimental trial, and other relevant matters. He said he wanted to use the documents to prepare for his case and argued that sealed documents involved in discovery should be accessible to the parties.

Jurisdiction

The court first considered whether it had authority to decide the motions while the appeal was pending. It explained that a notice of appeal generally removes the district court’s jurisdiction over matters involved in the appeal. Because Kahsai had appealed the final summary-judgment order, the court held that it lacked jurisdiction to consider his later motions to unseal documents.

Alternative Reasons for Denial

The court stated that it would deny the motions even if it had jurisdiction. Because it was unclear which documents Kahsai wanted unsealed, the court construed his request as possibly seeking either access to sealed exhibits on the case docket or an order compelling Dejoy to continue discovery.

The court explained that the sealed exhibits were available to the parties, their counsel, and the court, even though they were not publicly accessible. Although there is a common-law right to access judicial records, that right is not absolute and may be outweighed by interests supporting confidentiality. The court said that employment-discrimination disputes often contain sensitive personal information. It also found that Kahsai already had complete access to the sealed documents and could use them to prepare for his appeal, making his request to unseal them unnecessary.

The court also rejected any request to compel additional discovery. It had divided discovery into two phases: one concerning whether Kahsai’s claims were timely and another concerning the merits. After the first phase, the court found the claims untimely and granted summary judgment to Dejoy. Because that order was final and concluded the case, the court held that it could not compel discovery afterward.

Disposition

The court denied Kahsai’s Motion to De-Sealed Court Documents, Docket No. 120, and denied his Motion to Unseal Court Documents, Docket No. 124. The order did not decide the merits of the underlying employment-discrimination claims.