Coppinger v. Don Sanderson Ford Incorporated
2:25-cv-00100
D. Ariz.Apr 14, 2025Background
- Plaintiff Lynnsey Coppinger filed a complaint alleging that her boss, Adam Cox at Sanderson Lincoln, engaged in non-consensual sexual conduct with her after intoxicating her during a work trip.
- The complaint included claims of assault and battery against Cox and Sanderson Lincoln, and constructive discharge based on sex discrimination against Sanderson Lincoln.
- Plaintiff moved to seal the complaint due to the sensitive nature and her inability to recall some events, with the intent to voluntarily dismiss the action if the sealing was granted.
- The Court denied the motion to seal, finding no compelling reasons to override the public’s right of access to judicial records.
- Plaintiff then voluntarily dismissed the case, and Defendants filed a motion for reconsideration of the denial to seal the complaint, raising new arguments about reputational harm and the allegedly false nature of the allegations.
- The Court denied the motion for reconsideration, leaving the case closed and records unsealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to seal the complaint | Sensitive allegations, plaintiff’s memory is unclear | Allegations are false, defamatory, harm to defendants’ reputation | No compelling reason to seal; public right of access prevails |
| Reconsideration of motion to seal | N/A (plaintiff did not seek reconsideration) | New arguments about harm and falsity of allegations | Reconsideration denied; no new facts or law, no clear error shown |
| Effect of plaintiff’s memory lapse | Memory is "not fully or clear" due to intoxication | Plaintiff’s recollection is unreliable, entire complaint undermined | Court found allegations supported by additional facts and context |
| Settlement as basis for sealing | N/A | Confidential settlement warrants sealing | Settlement interests do not justify sealing judicial records |
Key Cases Cited
- Kamakana v. City & Cty. of Honolulu, 447 F.3d 1172 (9th Cir. 2006) (Embarrassment, incrimination, or litigation risk does not compel sealing of court records)
- Foltz v. State Farm Mut. Auto. Ins. Co., 331 F.3d 1122 (9th Cir. 2003) (Confidential settlements are not a compelling reason to seal court records)
- Brown v. Advantage Eng’g, Inc., 960 F.2d 1013 (11th Cir. 1992) (Once a lawsuit is filed, records become public, overriding private settlement secrecy)
- Green Acres Tr. v. London, 688 P.2d 617 (Ariz. 1984) (Statements in pleadings are privileged when related to the case subject matter)