Vantage Health Plan, Inc. v. Willis-Knighton Med. Ctr., 913 F.3d 443

Humana, a non-party, was subpoenaed under Rule 45 in an antitrust suit and ordered to produce ~50 documents (emails, draft contracts) allegedly evidencing an agreement with defendant Willis‑Knighton.
The district court issued and then amended a protective order after finding routine, boilerplate sealing requests; it required specific justification or leave to file under seal and placed the burden on designating parties to explain confidentiality when challenged.
The court held multiple hearings, examined the disputed documents line‑by‑line, and ruled none should be entirely sealed; limited redactions were ordered to protect reimbursement rates, fee schedules, percentage increases, and bonus amounts.
Humana failed to provide specific, document‑level justifications at the hearings and appealed the unsealing/redaction order as an interlocutory appeal.
The Fifth Circuit concluded it had collateral‑order jurisdiction because unsealing is effectively unreviewable on appeal from final judgment and third parties lack adequate alternative remedies; it reviewed the district court’s order for abuse of discretion and affirmed.

Issue	Plaintiff's Argument (Humana)	Defendant's Argument (District Court/Vantage)	Held
Appellate jurisdiction over interlocutory sealing/unsealing order	Order is immediately appealable under the collateral order doctrine because disclosure is irreparable	Sealing orders generally are not final; but unsealing is effectively unreviewable so collateral order applies	Court has collateral‑order jurisdiction; appeal permitted
Standard of review for sealing/unsealing	District court misapplied standards and overrode confidentiality protections	Review is abuse of discretion; district court properly balanced interests and followed procedure	Abuse‑of‑discretion standard applies; no abuse found
Burden / presumption of public access	Humana argued disclosure would reveal competitively sensitive info and required strong showing to seal	Public access presumption exists but Fifth Circuit refuses to treat it as a heightened burden; case‑by‑case balancing required	Humana’s conclusory assertions insufficient; district court permissibly required specific showings and redacted sensitive data
Whether court needed a separate "judicial record" finding before ordering unsealing	Humana argued court had to first declare documents judicial records before ruling on sealing	Court ruled it may decide in advance whether documents, if filed, would be sealed; a document becomes a judicial record when filed	No gateway error; district court properly ruled in advance and later protected filings via redaction

Digital Equipment Corp. v. Desktop Direct, 511 U.S. 863 (recognizes narrow collateral‑order exceptions)
Mohawk Industries, Inc. v. Carpenter, 558 U.S. 100 (limits collateral‑order doctrine; discusses effective unreviewability)
Nixon v. Warner Communications, Inc., 435 U.S. 589 (trial court discretion over public access to records)
United States v. Holy Land Foundation for Relief & Dev., 624 F.3d 685 (abuse‑of‑discretion review of sealing decisions)
United States v. Sealed Search Warrants, 868 F.3d 385 (Fifth Circuit’s approach to sealing and need for specific reasons)
Securities & Exchange Commission v. Van Waeyenberghe, 990 F.2d 845 (presumption of public access; judicial records concept)
Belo Broadcasting Corp. v. Clark, 654 F.2d 423 (deference to trial court on sealing; manage courtroom procedure)
Heinsohn v. Carabin & Shaw, P.C., 832 F.3d 224 (abuse‑of‑discretion criteria for district court decisions)