Samson v. UnitedHealthCare Services Inc
2:19-cv-00175
W.D. Wash.Nov 18, 2024Background
- Frantz Samson brings a class action against United Healthcare Services (UHC) alleging violations of the Telephone Consumer Protection Act (TCPA).
- The Court had previously certified two classes: the “Wrong Number Class” and the “Do Not Call Class.”
- UHC later filed a motion to decertify these classes, which led to both sides submitting documents and information that they sought to keep sealed.
- The parties subsequently reached a settlement in principle, and the motion to decertify was withdrawn, but the Court still needed to decide which previously filed information should remain sealed.
- Materials sought to be sealed included call transcripts, call audio recordings, and third-party data, some of which potentially implicated personal and medical privacy concerns.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Seal call transcripts | Should seal to protect member privacy | Should seal for PII and HIPAA-covered information | Granted; call transcripts remain sealed due to compelling privacy and medical grounds |
| Seal third-party telecommunications data | No explicit compelling reason given | Sealing needed to respect third parties’ confidentiality | Denied; no compelling reason, and third parties did not request sealing |
| Seal call audio recordings | Should be sealed because they cannot be redacted | Agreed recordings should be kept under seal | Granted in part; kept temporarily sealed pending request to unseal |
| Seal UHC-designated confidential info | Information previously sealed, still confidential | Agreed information should remain sealed | Granted; information remains sealed as before |
Key Cases Cited
- Nixon v. Warner Commnc’ns, Inc., 435 U.S. 589 (right of public access to court records)
- Foltz v. State Farm Mut. Auto. Ins. Co., 331 F.3d 1122 (presumption of public access in court records)
- Kamakana v. City & Cty. of Honolulu, 447 F.3d 1172 (courts must find a compelling reason to seal judicial records)
