Kinney v. Atlanticus Services Corporation

CourtDistrict Court, D. Minnesota
DecidedApril 30, 2025
Docket0:23-cv-03188
StatusUnknown

This text of Kinney v. Atlanticus Services Corporation (Kinney v. Atlanticus Services Corporation) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kinney v. Atlanticus Services Corporation, (mnd 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Mark Kinney Case No. 23-cv-3188 (DWF/DJF)

Plaintiff,

v. ORDER

Atlanticus Services Corporation,

Defendant.

This matter is before the Court on the parties’ Joint Motion Regarding Continued Sealing (“Sealing Motion”) (ECF No. 43) filed in connection with Defendant’s Motion for Summary Judgment (ECF No. 23). Defendant filed its Motion for Summary Judgment (ECF No. 23), supporting and reply memoranda (ECF Nos. 25, 38), meet and confer statement (ECF No. 28), proposed order (ECF No. 29), affidavit and thirty-four attached exhibits (ECF Nos. 27, 27-1 to 27-34), and declaration and four attached exhibits (ECF Nos. 40, 40-1 to 40-4) under seal. Defendant also filed statements indicating that redacting the documents was impractical (ECF Nos. 30, 31, 41). Plaintiff filed its responsive memorandum (ECF No. 32) and supporting declaration (ECF No. 33) with thirteen attached exhibits, all filed as a single document (ECF No. 33-1), under seal. Plaintiff also filed statements that redacting its documents was impractical (ECF No. 31, 34). Judge Donovan Frank granted in part and denied in part Defendant’s underlying Motion for Summary Judgment on March 18, 2025 (ECF No. 44). The parties agree to the following: (1) Defendant’s Motion for Summary Judgment should remain sealed because it “outlines Plaintiff’s claims against Defendant and alludes to supporting paperwork that has substantial amounts of confidential information Defendant requests to remain under seal”; (2) Defendant’s supporting and reply memoranda should remain sealed because they contain details of Plaintiff’s employment which are subject to Nondisclosure Agreements (“NDAs”), and redaction is impractical based on the length of the documents and numerous references to protected information; (3) Defendant’s affidavit and thirty-four attached exhibits should remain sealed because they have “various references to and evidence of client and prospective client

communication that are subject to NDAs”, and “there are entire deposition transcripts outlining, in part, Defendant’s business practices and engagement with current and prospective clients” and “the number of exhibits attached” makes the entire filing impractical to redact; (4) Defendant’s meet and confer statement should remain sealed because it contains agreements between the parties subject to Federal Rule of Civil Procedure 408 regarding settlement communications; (5) Defendant’s proposed order should be unsealed; (6) Defendant’s declaration and four attached exhibits should remain sealed because they contain references to and evidence of confidential communications subject to NDAs; (7) Plaintiff’s responsive memorandum should remain sealed because it “repeatedly discussed and references” documents that Defendant has designated as confidential, and redacting the information is impractical; and (8) Plaintiff’s declaration and thirteen attached exhibits

should remain sealed because “Defendant contends that all of them are confidential and subject to the Protective Order entered in this case and further protected by a Nondisclosure Agreement that Plaintiff signed” and that redacting them is impractical. (ECF No. 43 at 1-5.) I. Legal Standard Parties may seal documents in a civil case “only as provided by statute or rule, or with leave of court.” L.R. 5.6(a)(1). “There is a common-law right of access to judicial records.” IDT Corp. v. eBay, 709 F.3d 1220, 1222–23 (8th Cir. 2013) (citing Nixon v. Warner Commc'ns, Inc., 435 U.S. 589, 597 (1978)). But the right of access is not absolute. Id. at 1123. The Court “‘must consider the degree to which [the relief requested] would interfere with the interests served by the common-law right of access and balance that interference against the salutary interests served by maintaining confidentiality of the information.’” Cajune v. Indep. Sch. Dist. 194, 105 F.4th 1070, 1077 (8th Cir. 2024) (quoting IDT Corp., 709 F.3d at 1223). “[T]he weight to be given to the presumption of [public] access must be governed by the role of the material at issue in the exercise of Article III

judicial power and resultant value of such information to those monitoring the federal courts.” Id. at 1224 (quoting United States v. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995)). When the documents at issue play a material role in the exercise of Article III power or are of value to those monitoring the federal courts, “the presumption of public access to judicial records may be overcome if the party seeking to keep the records under seal provides compelling reasons for doing so.” Flynt v. Lombardi, 885 F.3d 508, 511 (8th Cir. 2018). On the other hand, when the documents at issue do not play a material role in the exercise of Article III power or are of little value to those monitoring the courts, the presumption of public access instead “amounts to … a prediction of public access absent a countervailing reason.” IDT Corp., 709 F.3d at 1224 (quoting United States v. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995)).

II. Analysis Because all the documents at issue are connected to a dispositive motion and the exercise of Article III power, they are of particular value to those monitoring the federal courts, such that the presumption for public access may be overcome only if the parties provide a compelling reason to keep them sealed. Flynt, 885 F.3d at 511. The Court concludes that the parties have proffered compelling reasons as to some, but not all, of the documents they seek to keep sealed. 1. Defendant’s Documents The parties agree that Defendant’s proposed order (ECF No. 29) may be unsealed. Based on the Court’s review of Defendant’s proposed order (ECF No. 29), and in light of the parties’ agreement, the Court finds unsealing it is appropriate. Flynt, 885 F.3d at 511. Upon reviewing Defendant’s remaining documents, the Court finds the parties have proffered sufficient justification for sealing only the following: (1) the meet and confer statement (ECF No. 28), because it contains statements that might be construed as confidential settlement

communications subject to Fed. R. Civ. P. 408; and (2) Defendant’s declaration and four attached exhibits (ECF Nos. 40, 40-1 to 40-4), because they contain references to and evidence of confidential communications subject to Nondisclosure Agreements, IDT Corp., 709 F.3d at 1221 (finding sensitive business information subject to continued sealing). The Court cannot conclude at this time that there is a compelling reason to keep Defendant’s other documents under seal. While the parties claim Defendant’s Motion for Summary Judgment should remain sealed because it “outlines Plaintiff’s claims against Defendant and alludes to supporting paperwork that has substantial amounts of confidential information Defendant requests to remain under seal”, it does not contain anything not already stated in Plaintiff’s publicly-filed Complaint. The Court is also unpersuaded by the parties’ broad assertion that Defendant’s

supporting and reply memoranda (ECF Nos. 25, 38) are simply too long and contain too much confidential information to redact.

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Related

Nixon v. Warner Communications, Inc.
435 U.S. 589 (Supreme Court, 1978)
United States v. Amodeo
71 F.3d 1044 (Second Circuit, 1995)
IDT Corp v. AR Public Law Center
709 F.3d 1220 (Eighth Circuit, 2013)
Larry Flynt v. George Lombardi
885 F.3d 508 (Eighth Circuit, 2018)
Bob Cajune v. ISD 194
105 F.4th 1070 (Eighth Circuit, 2024)

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Kinney v. Atlanticus Services Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kinney-v-atlanticus-services-corporation-mnd-2025.