Center for Auto Safety v. Chrysler Group, LLC
809 F.3d 1092
| 9th Cir. | 2016Background
- Plaintiffs filed a putative class action against Chrysler alleging a defective auto part and sought injunctive relief; parties entered a stipulated protective order allowing documents to be designated confidential.
- Plaintiffs moved for a preliminary injunction; both sides filed confidential discovery materials under seal per the protective order; the district court denied the injunction.
- The Center for Auto Safety (CAS) moved to intervene and to unseal the documents attached to the preliminary-injunction briefing, arguing the "compelling reasons" standard applies.
- The district court treated the preliminary-injunction motion as nondispositive, applied the lower "good cause" Rule 26(c) standard, and denied CAS’s motions.
- The Ninth Circuit reviewed whether the district court applied the correct sealing standard and concluded the public-access presumption applies where a motion is more than tangentially related to the merits.
- The panel vacated and remanded, directing the district court to reevaluate the sealed documents under the "compelling reasons" standard; it also vacated the denial of intervention for reconsideration.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard for sealing judicial records attached to motions | Sealed materials attached to a motion more than tangentially related to the merits are subject to the public's presumptive access and thus require "compelling reasons" to remain sealed | Sealed discovery attachments to nondispositive motions need only satisfy Rule 26(c) "good cause"; "dispositive" should be read literally and narrowly | The court held that the applicable test turns on whether the motion is more than tangentially related to the merits; if so, the strong presumption of access applies and the party seeking secrecy must show "compelling reasons" |
| Whether a preliminary injunction is subject to the presumption of access | Preliminary injunctions often address substantive rights and thus trigger the presumption when they are more than tangentially related | Because preliminary injunctions are technically nondispositive, the district court may apply the lower "good cause" standard | The Ninth Circuit held the preliminary-injunction motion at issue was more than tangentially related to the merits and remanded for application of the "compelling reasons" test |
| Proper deference/standard of review on unsealing | CAS sought access and intervention; appellate review of sealing decisions is for abuse of discretion but legal standards reviewed de novo | Chrysler defended the district court's legal determination to apply "good cause" | The panel reviewed the legal test de novo, found the district court applied the wrong standard, vacated and remanded |
| Effect on protective orders and Rule 26(c) | CAS: public access principle should not be swallowed by a broad discovery exception | Chrysler: narrowing "compelling reasons" to few literal dispositive motions protects reliance on protective orders and Rule 26(c) | The court balanced precedent and circuits and rejected a literal dispositive/nondispositive binary; protective orders remain valid but must yield where a motion meaningfully addresses merits and compelling reasons are absent |
Key Cases Cited
- Kamakana v. City & County of Honolulu, 447 F.3d 1172 (9th Cir. 2006) (articulates presumption of public access and the "compelling reasons" standard for dispositive motions)
- Foltz v. State Farm Mut. Auto. Ins. Co., 331 F.3d 1122 (9th Cir. 2003) (discusses the discovery exception and application of Rule 26(c) "good cause" to nondispositive motions)
- Phillips ex rel. Estates of Byrd v. Gen. Motors Corp., 307 F.3d 1206 (9th Cir. 2002) (held that sealed discovery documents attached to nondispositive motions fall within the discovery exception)
- Nixon v. Warner Communications, Inc., 435 U.S. 589 (1978) (recognizes a general public right to inspect judicial records but not absolute)
- United States v. Amodeo (Amodeo II), 71 F.3d 1044 (2d Cir. 1995) (frames access as a continuum and ties weight of presumption to role of material in adjudication)
- In re Midland Nat’l Life Ins. Co. Annuity Sales Practices Litig., 686 F.3d 1115 (9th Cir. 2012) (refused to let a technical nondispositive label control when the filing bore on central issues)
- Oliner v. Kontrabecki, 745 F.3d 1024 (9th Cir. 2014) (addresses interlocutory appeals from sealing orders and applies the compelling-reasons standard)
- Pintos v. Pacific Creditors Ass’n, 605 F.3d 665 (9th Cir. 2010) (acknowledges that "compelling reasons" applies to most judicial records)