Unreported / Non-Citable
Background
Craig Rowell, Alaina Aikin, and Sanjay Garg sued Labcorp Central Laboratory Services Limited Partnership in the Northern District of California over claims arising from their employment. Both sides moved for summary judgment, and each then filed an administrative sealing motion about material attached to its own motion. Labcorp's motion asked to seal seven documents and redact portions of eight others. Plaintiffs' motion was a Civil Local Rule 79-5(f) request asking the court to consider whether Labcorp's confidential material should be sealed; plaintiffs said they did not seek sealing and believed the public had a right to know the facts.
Labcorp supported its request with a declaration from its Senior Director of Sales Compensation. The materials fell into three groups: Labcorp's Sales Compensation Plans (Exhibits A through E to the Gascon Declaration), plaintiffs' new-hire offer letters (Exhibit F to that declaration), and documents identifying clients, contract values, and the studies or clinical trials those clients conducted. Labcorp argued that disclosing the plans would let competitors offer its employees similar packages, and that disclosing client information would give competitors an advantage in bidding and could harm the clients' standing in the research industry. In a footnote to their summary judgment opposition, plaintiffs opposed sealing the plan documents, citing California Labor Code sections 232 and 232.5. Fifteen exhibits to plaintiffs' own motion, which were the same compensation plans, had not been filed unredacted on the public docket. Labcorp filed no response to plaintiffs' motion.
The Court’s Holding
The court held that the compelling reasons standard governed both motions because summary judgment motions and their attachments are more than tangentially related to the merits, and it treated Civil Local Rule 79-5 as supplementing that standard. It granted Labcorp's motion in part. It ordered sealed Exhibits A through E to the Gascon Declaration and Exhibits 4 and 5 to the Meunier Declaration. It also approved redactions to paragraphs 12 through 14 of the Meunier Declaration, Meunier Exhibits 1 through 3, part of Gascon Exhibit K, Labcorp's separate statement of facts, and its summary judgment motion. The court reasoned that client and sales information and the details of a non-public compensation plan are competitively sensitive, citing other Northern District decisions. Because redacted versions were already public, no further filing was needed for those items.
The court denied the request to redact Gascon Exhibit F, plaintiffs' offer letters. It noted that Labor Code section 232 bars an employer from prohibiting an employee from disclosing the amount of the employee's wages, and that Labcorp's declaration did not explain why sealing the letters was necessary. Labcorp must file a version without redactions to plaintiffs' compensation amounts on the public docket within four days. The court then granted plaintiffs' motion and sealed the fifteen exhibits (Rowell Exhibits E through I, Garg Exhibits J through N, and Aikin Exhibits P through T), because they were the same compensation plans it had already found sealable. It noted Labcorp's silence but did not rest its ruling on it. The order resolves only sealing and does not decide either summary judgment motion.
Key Takeaways
- Sealing requests tied to summary judgment filings face the compelling reasons standard, not the lower good cause test that applies to non-dispositive motions.
- Non-public compensation plan details and client-specific sales data can meet that standard when the designating party explains the competitive harm it fears.
- Confidentiality claims fail where the declaration does not justify them and state law protects disclosure; here Labor Code section 232 and the lack of any explanation defeated redaction of wage amounts in offer letters.
- A party that files material another party designated confidential must use the Rule 79-5(f) procedure, and the court will decide sealing on its own review even if the filing party does not ask for it.
- The relief was tailored: some documents were sealed entirely, others redacted, and one redaction request was denied with a four-day deadline to file a public version.
Why It Matters
The order shows how a Northern District magistrate judge sorts competing confidentiality claims in an employment case at the summary judgment stage. Compensation plans and client data received protection, while individual employees' own pay figures did not, which reflects the statutory right to discuss wages.
The ruling is limited to sealing. It leaves the merits of the underlying employment claims, and plaintiffs' challenge to the plan terms, for the court's later summary judgment decision. Because it is a docket-management order, it mainly illustrates how courts apply existing Ninth Circuit sealing standards rather than creating new law.