Christopher Votapek v. USAA Casualty Insurance Company

District Court, S.D. California·Decided April 6, 2026·No. 3:23-cv-01221·Unknown

Opinion

CHRISTOPHER VOTAPEK, Case No. 23-cv-01221-BAS-JLB

Plaintiff, ORDER GRANTING PLAINTIFF’S v. MOTION TO SEAL (ECF No. 133) COMPANY, a Texas corporation, Defendant. Before the Court is Parties’ joint motion to seal portions of Plaintiff Christopher Votapek’s opposition to Defendant USAA Casualty Insurance Company’s motion for summary judgment and several accompanying exhibits (“Motion to Seal”). (ECF No. 133.) For the reasons below, the Court GRANTS Plaintiff’s Motion to Seal. (Id.) “[T]he courts of this country recognize a general right to inspect and copy public records and documents, including judicial records and documents.” Nixon v. Warner Commc’ns, Inc., 435 U.S. 589, 597 (1978). “Unless a particular court record is one ‘traditionally kept secret,’ a ‘strong presumption in favor of access’ is the starting point.” Kamakana v. City & Cnty. of Honolulu, 447 F.3d 1172, 1178 (9th Cir. 2006) (citing Foltz v. State Farm Mut. Auto Ins. Co., 331 F.3d 1122, 1135 (9th Cir. 2003)). “The presumption of access is ‘based on the need for federal courts, although independent—indeed, particularly because they are independent—to have a measure of accountability and for the public to have confidence in the administration of justice.’” Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092, 1096 (9th Cir. 2016) (quoting United States v. Amodeo, 71 F.3d 1044, 1048 (2d Cir. 1995)). A party seeking to seal a judicial record bears the burden of overcoming the strong presumption of access. Foltz, 331 F.3d at 1135. The showing required to meet this burden depends upon whether the documents to be sealed relate to a motion that is “more than tangentially related to the merits of the case.” Ctr. for Auto Safety, 809 F.3d at 1101. In other words, the presumption of public access fully applies to “dispositive pleadings,” such as “motions for summary judgment and related attachments.” Kamakana v. City & Cnty. of Honolulu, 447 F.3d 1172, 1179 (9th Cir. 2006). However, the Ninth Circuit has “carved out an exception to the presumption of access” to judicial records for a “sealed discovery document [attached] to a non-dispositive motion,” such that “the usual presumption of the public's right of access is rebutted.” Id. at 1179 (citing Foltz, 331 F.3d at 1135). The Ninth Circuit, thus, applies different standards for evaluating requests to seal documents accompanying dispositive motions and those accompanying non-dispositive motions. Kamakana, 447 F.3d at 1179. When the underlying motion is more than tangentially related to the merits (i.e., a dispositive motion), the “compelling reasons” standard applies. Id.; see also Ctr. for Auto Safety, 809 F.3d 1092 at 1096–98. “In general, ‘compelling reasons’ sufficient to outweigh the public’s interest in disclosure and justify sealing court records exist when such ‘court files might have become a vehicle for improper purposes,’ such as the use of records to gratify private spite, promote public scandal, circulate libelous statements, or release trade secrets.” Kamakana, 447 F.3d at 1179 (quoting Nixon, 435 U.S. at 598). However, when the underlying document is a non- dispositive motion, the “good cause” standard applies, and a district court may issue “any order which justice requires to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense.” Id. at 1180. A. Procedural Requirements The Court’s Standing Order notes, “[t]he fact that both sides agree to seal a document or that a stipulated protective order was issued is insufficient cause for sealing.” Standing Order § 5.A (“§ 5.A”). “Parties often seek to seal a document only because another party designated the document as sensitive under a protective order . . . [i]n these circumstances, the moving party must first meet and confer with the designating party to determine whether the designating party maintains that any portion of the document must be filed under seal.” Id. Then, “the designating party must file a response to the sealing motion within seven days that satisfies the sealing standard . . . If no response is filed, the Court may order that the document be filed in the public record.” Id. Though the Court previously denied Plaintiff’s motion to seal on the basis that it failed to demonstrate Plaintiff satisfied § 5.A’s meet-and-confer requirement, the Court finds Parties’ renewed motion to seal satisfies § 5.A. (See ECF No. 133 at 2:23–3:11.) Further, given that the renewed motion to seal is jointly filed by Parties, the Court finds Defendant (the designating party) does not need to file a response to the sealing motion within seven days. B. Related Documents More Than Tangentially Related to Merits Plaintiff’s proposed redactions and documents to seal are filed in connection with Plaintiff’s summary judgment motion (ECF Nos. 116, 133). See Pac. Marine Propellers, Inc. v. Wartsila Def., Inc., No. 17-CV-555-L-NLS, 2018 WL 11457880, at *1 (S.D. Cal. Nov. 5, 2018) (“The compelling reasons standard applies to all motions except those that are only ‘tangentially related to the merits of a case.’. . . Defendants’ summary judgment motion is more than tangentially related to the merits”) (citing Kamakana, 447 F.3d at 1179). As such, the Court finds Plaintiff’s motion to seal (ECF No. 125) is subject to the “compelling reasons” standard in Kamakana, 447 F.3d at 1179. C. “Compelling Reasons” Analysis Here, Plaintiff moves to seal portions of its opposition to Defendant’s motion for summary judgment and accompanying exhibits because such materials contain either: (1) “USAA’s confidential, proprietary, trade secret information relating to internal policies and procedures,” or, (2) “Golshani Lee LLP’s confidential, proprietary, trade secret information regarding the terms of engagement with client.” (See ECF No. 125 at 2:18– 4:5.) 1. USAA’s Internal Policies and Procedures Preventing the release of trade secrets generally constitutes a compelling reason to seal such documents. Kamakana, 447 F.3d at 1179; see also Nixon, 435 U.S. at 598 (observing that the “common-law right of inspection has bowed before the power of a court to insure that its records” are not used as “sources of business information that might harm a litigant's competitive standing”); Apple Inc. v. Samsung Elecs. Co., 727 F.3d 1214, 1226– 28 (Fed.Cir.2013) (holding that under Ninth Circuit law, detailed product-specific information and internal reports are appropriate to seal under the “compelling reasons” standard where that information could be used to the company's competitive disadvantage). Insurance company claim manuals that are not publicly available can qualify as trade secrets that are sealable under the compelling reasons standard. See e.g., McCall v. State Farm Mut. Auto. Ins. Co., No. 216CV01058JADGWF, 2017 WL 3174914, at *11 (D. Nev. July 26, 2017) (collecting cases); see also e.g., Guessford v. Pennsylvania Nat. Mut. Cas. Ins. Co., No. 1:12CV260, 2013 WL 2242988, at *4 (M.D.N.C. May 21, 2013); see also e.g., Las Vegas Sands, Inc. v. Nat'l Union Fire Ins. Co., No. 2:22-CV-00461-JCM-BNW, 2023 WL 6929303, at *2 (D. Nev. Oct. 19, 2023) (quoting Chavez v. Standard Ins. Co., No. 3:18-CV-2013, 2020 WL 6382611, at *2 (N.D. Tex. Oct. 30, 2020)) (“Courts have routinely held that insurer's claims-handling guidelines are trade secrets”). Here, Parties move to seal portions of Plaintiff’s opposition motion to Defendant’s motion for summary judgment and Exhibit 7, and the entirety of

Free access — add to your briefcase to read the full text and ask questions with AI

Christopher Votapek v. USAA Casualty Insurance Company, (S.D. Cal. 2026).

Christopher Votapek v. USAA Casualty Insurance Company (Christopher Votapek v. USAA Casualty Insurance Company) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related