Fair Laboratory Practices Asso v. Chris Riedel
666 F. App'x 209
| 3rd Cir. | 2016Background
- FLPA (Fair Laboratory Practices Associates) and Hunter Laboratories (Hunter) were parties to a profit-sharing agreement splitting proceeds from qui tam suits against Quest Diagnostics; FLPA sued Hunter in D.N.J. seeking 15% of a prior California settlement Hunter received.
- Quest, a nonparty, sought to appear as amicus and asked the court to donate funds to charity based on FLPA’s prior unethical conduct; the court denied Quest’s requests and entered summary judgment for FLPA.
- Two months after final judgment, FLPA and Hunter stipulated they had settled and asked the court to vacate its judgment to reflect their settlement terms that purportedly related to their future sharing relationship.
- The District Court requested the parties file their settlement agreement; FLPA and Hunter did so and moved to seal it. Quest intervened and opposed sealing.
- The District Court granted intervention but sealed the filed settlement, reasoning the agreement would not have been filed but for the court’s request and the parties assumed confidentiality.
- The Third Circuit vacated the sealing order and remanded for further proceedings, holding the court erred in failing to balance the public’s presumptive right of access against particularized confidentiality interests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the filed settlement agreement should be sealed | FLPA: filing was prompted by the court; parties assumed confidentiality; sealing preserves settlement expectations | Quest: public has presumptive right to access judicial records; no particularized harm shown | Sealing vacated; remand to balance public access against specific confidentiality interests |
| Whether a court’s request to file a document justifies sealing | FLPA: Court’s request and parties’ assumption of confidentiality supports sealing | Quest: Court request does not override presumption of public access absent specific harm | Court: Request to file is not by itself sufficient to overcome the presumption of access |
| Whether general interest in encouraging settlement justifies sealing | FLPA: confidentiality encourages settlement and should weigh in favor of sealing | Quest: General settlement policy cannot justify sealing without particularized showing | Court: General settlement encouragement is insufficient; party must show disclosure would cause clearly defined, serious injury |
| Whether less-restrictive alternatives (e.g., redaction) should be considered | FLPA: full sealing protects expectations | Quest: redaction or limited sealing could protect privacy while preserving public access | Court: Remanded to consider less-restrictive means such as redaction before full sealing |
Key Cases Cited
- LEAP Sys., Inc. v. MoneyTrax, Inc., 638 F.3d 216 (3d Cir. 2011) (articulates presumption of public access to judicial records and need for particularized showing to overcome it)
- In re Cendant Corp., 260 F.3d 183 (3d Cir. 2001) (court cannot rely on general interest in encouraging settlement to justify sealing)
- Pansy v. Borough of Stroudsburg, 23 F.3d 772 (3d Cir. 1994) (requires particularized showing for confidentiality in settlement contexts)
- Litteljohn v. Bic Corp., 851 F.2d 673 (3d Cir. 1988) (discusses public confidence served by open judicial records)
- Bank of Am. Nat’l Trust & Sav. Ass’n v. Hotel Rittenhouse Assocs., 800 F.2d 339 (3d Cir. 1986) (emphasizes tradition of open access to court documents and orders)
- Ohntrup v. Firearms Ctr., Inc., 802 F.2d 676 (3d Cir. 1986) (jurisdictional principle for appeals of orders resolving post-judgment disputes)
- United States v. Quest Diagnostics Inc., 734 F.3d 154 (2d Cir. 2013) (affirming dismissal based on plaintiff’s unethical conduct; contextual case referenced in background)