EQUAL EMPLOYMENT OPPORTUNITY COMMISSION v. LOFLIN FABRICATIONS, LLC

District Court, M.D. North Carolina·Decided July 8, 2020·No. 1:18-cv-00813·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

EQUAL EMPLOYMENT ) OPPORTUNITY COMMISSION, ) ) Plaintiff, ) ) v. ) 1:18-CV-813 ) LOFLIN FABRICATION LLC, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER Catherine C. Eagles, District Judge. In this employment discrimination case arising out of a prescription drug disclosure policy and the termination of claimant Deborah Shrock, each party asks the Court to seal certain documents containing purported medical or personal information filed in connection with summary judgment briefing. The motion will be granted as to all personal medical information of the claimant that is unrelated to the issues in this case and of the claimant’s co-workers. It will otherwise be denied. Background Upon filing its motion for summary judgment, Doc. 33, the defendant Loflin Fabrication LLC filed a redacted brief and certain redacted exhibits, along with a motion to seal the unredacted versions of the brief and exhibits. Docs. 35 (motion to seal), 36 (unredacted memorandum), 36-1, 36-2, 36-3 (unredacted exhibits). The Court held a telephone conference and authorized the parties to file under temporary seal any briefs and exhibits that either party contended contained information that should be filed under seal, treating all such briefs and exhibits as covered by the already-filed motion at Doc. 35. Minute Entry 02/21/2020. The Court directed the party claiming confidentiality to file one brief addressing all information that party sought to seal after summary judgment

briefing concluded. Id. As required by LR 5.4, the parties complied. See Doc. 41 (EEOC brief); Doc. 44 (Loflin brief). Also as required by the Local Rules, the parties filed publicly available briefs with the information subject to the motion to seal redacted, as well as either redacted exhibits when that was feasible or, with a couple of exceptions, placeholders if they sought to seal the entire exhibit.1 Neither party objected to the other

party’s motion to seal. The public has had notice of the motion to seal for more than three months due to the publicly filed motion to seal and the parties’ publicly filed, redacted memoranda in support. Doe v. Pub. Citizen, 749 F.3d 246, 272 (4th Cir. 2014); Stone v. Univ. of Md. Med. Sys. Corp., 855 F.2d 178, 181 (4th Cir. 1988). The docket reflects no action by any

interested party to “seek intervention to contest any sealing order.” Cochran v. Volvo Grp. N. Am., LLC, 931 F. Supp. 2d 725, 728 (M.D.N.C. 2013). Analysis The public has a right of access to judicial records. Nixon v. Warner Commc’ns, Inc., 435 U.S. 589, 597 (1978) (“[T]he courts of this country recognize a general right to

1 This is not the case for Doc. 36-3, whose publicly available counterpart Doc. 34-4 contains only “excerpts” of the claimant’s deposition testimony and does not include redacted pages for the information the EEOC wants sealed. As the Court will direct the EEOC to file a redacted version of Doc. 36-3 that complies with the Court’s rulings as to this document, the EEOC need not file a redacted version for all statements they had originally sought to seal. Loflin also failed to file a placeholder exhibit for Doc. 36-1, which the Court will be unsealing. inspect and copy . . . judicial records and documents.”). All of the documents at issue here are judicial records because they were filed with the objective of obtaining judicial action or relief and play a role in the adjudicative process or adjudicate substantive rights.

See In re Application of the U.S. for an Order Pursuant to 18 U.S.C. Section 2703(D), 707 F.3d 283, 290 (4th Cir. 2013). The right of public access to judicial records derives from the First Amendment and the common law. Va. Dep’t of State Police v. Wash. Post, 386 F.3d 567, 575 (4th Cir. 2004). When a party asks to seal judicial records, the court “must determine the

source of the right of access with respect to each document,” and then “weigh the competing interests at stake.” Id. at 576 (quoting Stone, 855 F.2d at 181). The public has a First Amendment right of access to these documents because they were filed in connection with a motion for summary judgment. Virginia Dept. of State Police v. Washington Post, 386 F.3d 567, 578 (4th Cir. 2004); Rushford v. New Yorker Magazine,

Inc., 846 F.2d 249, 253 (4th Cir. 1988). The First Amendment right of access to judicial records “yields only in the existence of a compelling governmental interest . . . that is narrowly tailored to serve that interest.” In re Application, 707 F.3d at 290.2 The party seeking to limit public access bears the burden to show that sealing is appropriate, Pub. Citizen, 749 F.3d at 272;

Rushford, 846 F.2d at 253, and must provide specific reasons to support its position. Va. Dep’t of State Police, 386 F.3d at 575.

2 The Court omits internal citations, alterations, and quotation marks throughout this opinion, unless otherwise noted. See United States v. Marshall, 872 F.3d 213, 217 n.6 (4th Cir. 2017). The EEOC and Loflin assert the information at issue should be sealed because it contains personal and private medical information of a kind not ordinarily made public. This is an interest that may, in an appropriate case, override the public’s interest in access

to court records. See Boone v. Bd. of Governors of the Univ. of N.C., 395 F. Supp. 3d 657, 665 (M.D.N.C. 2019) (granting motion to seal medical records filed in connection with summary judgment in employment dispute). If a request is narrowly tailored, sensitive medical information may be sealed. Bell v. Shinseki, No. 1:12CV57, 2013 WL 3157569, at *9 (M.D.N.C. June 20, 2013), aff’d, 584 F. App’x 42 (4th Cir. 2014). The

documents the parties seek to seal are listed and cited in a chart at the end of this order. The EEOC seeks to seal several categories of information. Specifically, it seeks to seal the name of the claimant’s prescription drug at issue in her discharge; the results of the drug test that occurred just before her discharge; medical records related to her relevant neck pain and other irrelevant health conditions; and the names of medications

she was taking for unrelated conditions. As to her neck pain, the EEOC has narrowed its motion to seal, and it no longer seeks to seal some of the information so designated at its request when Loflin initially filed its brief and exhibits. See notes 3 & 4 infra. The publicly filed briefs and the Court’s decision disclose that the claimant was taking a muscle relaxant and that the drug test was negative. The EEOC has not

explained why the name of the muscle relaxant or the document confirming the negative drug test are otherwise sensitive information. As to this information, the motion to seal will be denied. The motion will also be denied as to the EEOC’s response to an interrogatory about the claimant’s disability. Doc. 36-1. This interrogatory answer largely puts forth relevant dates of treatment and diagnoses that are relevant to the Court’s summary

judgment decision, and it is difficult to justify keeping secret the nature of a claimed disability in a case involving alleged disability discrimination.

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EQUAL EMPLOYMENT OPPORTUNITY COMMISSION v. LOFLIN FABRICATIONS, LLC, (M.D.N.C. 2020).

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