Doe v. Noem
2:25-cv-01103
E.D. Cal.Jun 12, 2025Background
- Defendants sought to seal a joint stipulation for dismissal in a civil case involving Student Doe and Kristi Noem.
- The request to seal was made at the plaintiff's request, citing a protective order covering certain material and local court rules.
- Court documents are presumptively public, with sealing permitted only in narrow circumstances.
- Motions related to dispositive issues, such as stipulations for dismissal, require the higher "compelling reasons" standard to justify sealing.
- The court had previously found compelling reasons to seal only information identifying the plaintiff, not entire documents.
- The court decided that redaction, rather than complete sealing, would be a more appropriate approach unless further justification is provided.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the entire stipulation for dismissal should be sealed | Sealing required for plaintiff identity protection | Entire stipulation should be sealed due to protective order and sensitive info | Request denied without prejudice; redactions may suffice |
| Appropriate standard for sealing dispositive motions | N/A | Protective order justifies blanket sealing | "Compelling reasons" standard applies; require tailored sealing |
| Whether protective order mandates complete sealing | Protective order protects personal info, not all content | Protective order covers material in stipulation | Protective order is not blanket authority; only identifying info may be sealed |
| Whether defendants must provide specific justification for sealing | N/A | Protective order and plaintiff's request sufficient | Defendants must explain why more than redaction is needed |
Key Cases Cited
- San Jose Mercury News, Inc. v. U.S. Dist. Court, 187 F.3d 1096 (9th Cir. 1999) (establishing the presumption of public access to court records)
- Kamakana v. City & Cnty. of Honolulu, 447 F.3d 1172 (9th Cir. 2006) (articulating standards for sealing court records and requirements for compelling reasons)
- Nixon v. Warner Commc’ns, Inc., 435 U.S. 589 (1978) (explaining circumstances where court records may be sealed due to improper purposes)
- Pintos v. Pac. Creditors Ass’n, 605 F.3d 665 (9th Cir. 2010) (distinguishing standards for sealing dispositive vs. non-dispositive motions)
- Foltz v. State Farm Mut. Auto. Ins. Co., 331 F.3d 1122 (9th Cir. 2003) (discussing high threshold for sealing documents tied to dispositive motions)