King v. Hard Rock Cafe Int'l (USA), Inc.
2:24-cv-01119
| E.D. Cal. | Jul 28, 2025Background
- Christina King filed a request to seal her unredacted second amended complaint and accompanying exhibits in her lawsuit against Hard Rock Cafe International (USA), Inc.
- King sought to file these documents under seal without prior court authorization.
- King's main justification was that the complaint contained information about her hotel bookings, including precise dates, hotel location, number of guests, and check-in/check-out dates.
- She argued that this information constituted “guest record” information protected under California Civil Code § 53.5.
- The defendant, Hard Rock Cafe, did not file any opposition to the sealing request.
- The court found that none of the information, apart from King’s name, meets the statutory definition of “guest record” under California law and denied the request, ordering the unauthorized documents stricken and requiring King to file an unredacted version.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the complaint and exhibits can be sealed | Information is confidential under § 53.5 | No response | Denied: no compelling reasons established |
| Whether hotel booking info qualifies as a guest record | Booking details are protected under § 53.5 | No response | Denied: information does not qualify |
| Proper procedure for filing documents under seal | Did not follow required motion process | No response | Documents stricken as improperly filed |
| Need to redact personal data in complaint | Booking info needs confidentiality protection | No response | Unredacted complaint must be filed |
Key Cases Cited
- San Jose Mercury News, Inc. v. U.S. Dist. Court, 187 F.3d 1096 (9th Cir. 1999) (explains the presumption of public access to court records)
- Kamakana v. City & Cty. of Honolulu, 447 F.3d 1172 (9th Cir. 2006) (sets out the compelling reasons standard for sealing court records)
- Nixon v. Warner Commc’ns, Inc., 435 U.S. 589 (1978) (describes misuse of court files and grounds for sealing records)
