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Samson v. UnitedHealthCare Services Inc
2:19-cv-00175
W.D. Wash.
Nov 18, 2024
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Background

  • 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  • The parties subsequently reached a settlement in principle, and the motion to decertify was withdrawn, but the Court still needed to decide which previously filed information should remain sealed.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)
Read the full case

Case Details

Case Name: Samson v. UnitedHealthCare Services Inc
Court Name: District Court, W.D. Washington
Date Published: Nov 18, 2024
Docket Number: 2:19-cv-00175
Court Abbreviation: W.D. Wash.