Schoenadel v. YouGov America, Inc.

Background

Plaintiff Tracy Schoenadel sought permission to file 19 exhibits under seal in connection with her opposition to YouGov America, Inc.’s motion for summary judgment. She said the exhibits contained confidential YouGov client names, financial information, and information about YouGov’s compensation structure. The documents had been marked confidential or highly confidential under the parties’ protective order.

YouGov also asked that six additional documents be filed under seal and that two documents be filed with redactions. Schoenadel opposed those requests, arguing that the documents concerned evidence relevant to her allegations that YouGov had a pattern of discrimination and retaliation against women. The documents included communications about other employees’ discrimination complaints, an investigation of Schoenadel’s grievance, another employee’s internal grievance, an open letter signed by YouGov employees, and notes from a former employee’s exit interview.

Court’s Analysis

The court held that confidential financial and client information could be filed under seal. It relied in part on the parties’ protective order, which limited access to materials marked confidential.

The court explained that documents submitted for the court’s consideration on a summary-judgment motion are “judicial documents”—court materials to which the public generally has a strong right of access under both the common law and the First Amendment. The party seeking to seal such documents bears the burden of showing that sealing is justified. The court noted that YouGov had not responded to Schoenadel’s motion to explain why the disputed documents should be sealed. It also found that the documents concerned Schoenadel’s discrimination allegations and appeared to bear directly on the court’s decision in the case.

Ruling

The court stated, “Application granted.” It allowed the documents containing confidential financial and client information to be filed under seal. It also granted Schoenadel’s request concerning the other documents YouGov sought to seal, directing that those documents be refiled and made publicly available. The Clerk of Court was directed to terminate the motion at Docket 88. The opinion does not separately state the disposition of each proposed redaction by document.