Centene Pharmacy Services, Inc. v. CaremarkPCS Health, L.L.C.
4:24-cv-00804
| E.D. Mo. | Mar 31, 2025Background
- This case involves a contractual dispute between Centene Pharmacy Services, Inc. (plaintiff) and Caremark PCS Health, L.L.C. along with CVS Caremark Part D Services, L.L.C. (defendants), collectively referred to as “Caremark.”
- The primary dispute regards certain provisions within the parties’ contractual agreements.
- Both parties sought to file the complete petition and its exhibits under seal, citing concerns over sensitive business information (including trade secrets, customer data, and proprietary pricing).
- After conferring, the parties agreed to file an unredacted petition publically and only redact certain exhibits.
- The pending motion to dismiss relies solely on unredacted, public portions of the record.
- The court was tasked with balancing the common law right of public access to judicial records with the parties’ asserted need for confidentiality.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to seal petition and exhibits | Filing under seal necessary to protect business secrets | Filing under seal necessary to protect business secrets | Granted motion to seal; confidentiality outweighs public interest for now |
| Common-law right of access to judicial records | Sensitive materials are not central to adjudication | Sensitive materials are not central to adjudication | Right of access outweighed by non-dispositive nature of materials |
| Scope of public disclosure | Agrees to public filing of petition, redacts exhibits | Agrees to public filing of petition, redacts exhibits | Allows public petition, sealed exhibits as proposed |
| Potential to revisit sealing decision | No opposition to future review if material becomes relevant | No opposition to future review if material becomes relevant | Court reserves right to revisit sealing as needed |
Key Cases Cited
- Nixon v. Warner Commc’ns, Inc., 435 U.S. 589 (1978) (district courts may seal materials that disclose sources of business information harmful to competitive standing)
- IDT Corp. v. eBay, 709 F.3d 1220 (8th Cir. 2013) (discusses the presumption of access to judicial records and factors to weigh)
- Flynt v. Lombardi, 885 F.3d 508 (8th Cir. 2018) (standard for compelling reasons to overcome public right of access)
- In re Neal, 461 F.3d 1048 (8th Cir. 2006) (discusses factors for sealing court records)
- United States v. Amodeo, 71 F.3d 1044 (2d Cir. 1995) (articulates the continuum for sealing judicial materials)