Unreported / Non-Citable
Background
The notice of removal (ECF No. 1) included an attachment (ECF No. 1-1) containing images of plaintiffs' driver's licenses and related personal identifying information. On August 12, 2026, the assigned district judge granted plaintiffs' motion to remand the case back to Merced County Superior Court (ECF No. 36). Notwithstanding the remand, plaintiffs filed an unopposed motion to seal documents on the court's docket containing images of their driver's licenses (ECF No. 40). Plaintiffs identified the exhibits to ECF No. 6 as containing sensitive personal information; however, upon review, the court did not identify any personal or sensitive information in those documents warranting sealing. The court sua sponte identified images of the driver's licenses in the attachment to the notice of removal filed on July 1, 2026 (ECF No. 1-1) and construed plaintiffs' motion as a request to seal ECF No. 1-1.
Local Rule 141 governs requests to seal in the Eastern District of California, providing that documents may be sealed only by written order of the court upon the showing required by applicable law. The Ninth Circuit applies a "good cause" standard to requests to seal documents attached to non-dispositive motions, as established in Center for Auto Safety v. Chrysler Group, LLC, 809 F.3d 1092, 1096-98 (9th Cir. 2016). The court found that the exhibits attached to the notice of removal (ECF No. 1-1) contain images of plaintiffs' driver's licenses and related personal identifying information, which warrants protection under the good cause standard. The court cited Harrell v. George, No. CIV S-11-0253 MCE DAD PS, 2011 WL 2559416, at *2 (E.D. Cal. June 23, 2011), which found good cause to seal documents containing personal information, including a plaintiff's driver's license number.
The Court’s Holding
The court granted plaintiffs' motion to seal (ECF No. 40) and directed the Clerk of Court to seal ECF No. 1-1. The court determined that the driver's license images and personal identifying information contained in the attachment to the notice of removal constitute sensitive personal information warranting protection under the good cause standard. The order was entered by United States Magistrate Judge Stanley A. Boone on October 23, 2026.
The court's analysis focused on the specific content of ECF No. 1-1, distinguishing it from the exhibits to ECF No. 6 that plaintiffs had originally identified. By sua sponte identifying the driver's license images in the notice of removal attachment, the court exercised its discretion to protect personally identifiable information even though the underlying case had been remanded to state court. The ruling applies the Ninth Circuit's good cause standard for sealing documents attached to non-dispositive motions, consistent with Local Rule 141's requirement that documents may be sealed only by written order upon the showing required by applicable law.
Key Takeaways
- Courts may sua sponte identify and seal documents containing sensitive personal information even when the parties' motion targets different documents.
- Driver's license images and personal identifying information constitute good cause for sealing under Ninth Circuit precedent, even in cases that have been remanded to state court.
- Local Rule 141 requires a written order and a showing under applicable law to seal documents, with the Ninth Circuit applying a good cause standard for non-dispositive motion attachments.
- A federal court retains authority to rule on sealing motions for documents in its docket after remanding the underlying case to state court.
- The good cause standard for sealing is satisfied by the presence of personally identifiable information such as driver's license numbers and images.
Why It Matters
This order illustrates the court's proactive role in protecting personally identifiable information on its docket, even after a case has been remanded. The decision reinforces that the good cause standard under Ninth Circuit law extends to documents filed in connection with removal proceedings, not just merits-related filings. It also demonstrates that courts will construe sealing motions broadly to encompass any sensitive information in the record, regardless of whether the moving party precisely identified the correct docket entries. The ruling serves as a reminder to litigants and clerks to redact or avoid filing unredacted government-issued identification documents in public court records.