West v. City of Minneapolis
- David Doty
- 0:21-cv-01280
- U.S. District Court · District of Minnesota
- 3
In West v. City of Minneapolis, Judge Foster granted the parties’ motion to seal specified exhibits and ordered others unsealed or publicly filed.
The parties and anyone seeking public access to the exhibits filed in connection with the Daubert and summary-judgment motions; specified exhibits remain sealed, while others are to be unsealed or publicly filed with redactions.
What happened
West v. City of Minneapolis concerned the parties’ joint request about documents filed with a motion to exclude expert testimony and a motion for summary judgment. The parties agreed that some documents should remain sealed, while others could be unsealed or publicly filed with redactions.
The court granted the motion to seal. It kept Exhibits 8, 4 through 8, and the redacted police-report exhibit under seal; ordered the deposition transcript and an incorrectly filed placeholder unsealed after 28 days unless a timely motion was filed; marked the placeholder as filed in error; and ordered the parties’ proposed redacted police report publicly filed.
Judge Dulce J. Foster issued the order on May 8, 2024, after noting that the underlying case had already been dismissed before the documents were used in deciding the pending motions.
The detailed version
- West v. City of Minneapolis · No. 0:21-cv-01280
- David Doty
- May 8, 2024
Background
The court considered the parties’ Joint Motion to Seal documents filed in connection with Plaintiff’s Daubert motion to exclude expert testimony and Defendants’ motion for summary judgment. Plaintiff had filed two exhibits under seal. Defendants had filed several exhibits conventionally and under seal, including a police report and body-worn-camera videos. Defendants later stated that one sealed placeholder had been filed in error and submitted a redacted version of the police report.
The parties agreed that Plaintiff’s Exhibit 8 should remain sealed because it contained private medical information. They agreed that Plaintiff’s Exhibit 9, a deposition transcript, could be unsealed. They also agreed that the placeholder filed as ECF No. 137 could be unsealed and marked as filed in error; that Defendants’ Exhibits 4 through 8 should remain sealed because they were body-worn-camera videos protected under the Minnesota Government Data Protection Act; and that the police report should be publicly filed with additional redactions protecting personal information about people not involved in the lawsuit.
Court’s reasoning
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, subject to balancing public access against legitimate confidentiality interests. Because the case had been dismissed before the district judge ruled on the Daubert and summary-judgment motions, the documents had not played a role in the exercise of federal judicial power. After reviewing the documents, the court found good cause to keep the requested materials sealed because they contained sensitive private information or information protected and kept confidential under state law.
Ruling
The court granted the Joint Motion to Seal as follows:
- The Clerk was directed to keep ECF Nos. 125, 138, and 140 under seal.
- ECF Nos. 126 and 137 were to be unsealed 28 days after the order unless a timely motion for further consideration was filed under Local Rule 5.6(d)(3).
- ECF No. 137 was to be marked as filed in error.
- ECF No. 150-1 was to be publicly filed as Exhibit 2 to Defendants’ motion for summary judgment.
The order was signed by Dulce J. Foster, United States Magistrate Judge. The opinion states that the earlier dismissal of the matter was entered by the Honorable David S. Doty on April 22, 2024.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.