The Center for Auto Safety v. Chrysler Group, No. 15-55084 (9th Cir. 2016)
Annotate this CaseCAS appealed the district court's denial of its motion to intervene and unseal documents filed in a putative class action between Chrysler and certain named plaintiffs. In this case, the district court found that the motion for preliminary injunction here was nondispositive, applied the good cause standard to the documents filed under seal, and concluded that good cause existed to keep them from the public’s view. The court held, however, that a party seeking to seal a judicial record bears the burden of overcoming a strong presumption by meeting the compelling reasons standards where a court may seal records only when it finds compelling reasons and articulates the factual basis for its ruling, without relying on hypothesis or conjecture. The court must then conscientiously balance the competing interests of the public and the party who seeks to keep certain judicial records secret. When deciding what test to apply, the court sometimes deployed the terms "dispositive" and "non-dispositive." Public access to filed motions and their attachments did not depend on whether the motion was technically “dispositive;” but rather, public access turned on whether the motion was more than tangentially related to the merits of the case. Because the preliminary injunction motion here was more than tangentially related to the merits of the case, the court vacated and remanded for the district court to consider the documents under the compelling reasons standard.
Court Description: Sealed Documents. The panel vacated the district court’s order denying The Center for Auto Safety’s motions to intervene and unseal documents filed to support and oppose a motion for preliminary injunction in a putative class action between Chrysler Group, LLC and certain named plaintiffs, and remanded for further proceedings. A party seeking to seal a judicial record bears the burden of overcoming a strong presumption in favor of access to court records by showing “compelling reasons,” and the court must then balance the compelling interests of the public and the party seeking to keep the judicial record secret. Under an exception for sealed materials attached to a discovery motion unrelated to the merits of a case, a party seeking to seal the record need only satisfy a less exacting “good cause” standard. When deciding what test to apply to a motion to unseal a particular court filing – the presumptive “compelling reasons” standard or the “good cause” exception – the court has often deployed the terms “dispositive” and “non- dispositive.” The panel presumed that the instant motion for preliminary injunction was technically nondispositive. The panel held that public access to filed motions and their attachments did not depend on whether the motion was technically “dispositive;” but rather, public access turned on CENTER FOR AUTO SAFETY V. CHRYSLER GROUP 3 whether the motion was more than tangentially related to the merits of the case. The panel concluded that plaintiffs’ motion for preliminary injunction was more than tangentially related to the merits. The panel remanded for the district court to consider the documents under the compelling reasons standard. Concurring, District Judge Sessions wrote separately to express his belief that reversal was warranted even under the binary approach endorsed by the dissent because the preliminary injunction at issue was literally “dispositive” of plaintiffs’ request that Chrysler issue notice to its customers. Judge Ikuta dissented because she believed that the majority opinion overruled circuit precedent and vitiated Fed. R. Civ. P. 26(c). Judge Ikuta would employ the “binary approach” which holds that the public’s presumed right of access applied to sealed discovery documents attached to a dispositive motion, but did not apply to sealed discovery documents attached to a nondispositive motion.
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