Paul Sonico v. City of Brawley, et al.

CourtDistrict Court, S.D. California
DecidedMay 28, 2026
Docket3:25-cv-00515
StatusUnknown

This text of Paul Sonico v. City of Brawley, et al. (Paul Sonico v. City of Brawley, et al.) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Paul Sonico v. City of Brawley, et al., (S.D. Cal. 2026).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 PAUL SONICO, Case No. 25-cv-00515-BAS-LR

12 Plaintiff, ORDER GRANTING PARTIES’ 13 v. JOINT MOTION TO SEAL (ECF No. 43) 14 CITY OF BRAWLEY, et al., 15 Defendants. 16 17 Before the Court is Parties’ joint motion to seal certain exhibits related to 18 determining Defendants’ motion for summary judgment (“Motion to Seal”). (ECF No. 19 43.) For the reasons below, the Court GRANTS the Motion to Seal. (Id.) 20 I. LEGAL STANDARD 21 “[T]he courts of this country recognize a general right to inspect and copy public 22 records and documents, including judicial records and documents.” Nixon v. Warner 23 Commc’ns, Inc., 435 U.S. 589, 597 (1978). “Unless a particular court record is one 24 ‘traditionally kept secret,’ a ‘strong presumption in favor of access’ is the starting point.” 25 Kamakana v. City & Cnty. of Honolulu, 447 F.3d 1172, 1178 (9th Cir. 2006) (citing Foltz 26 v. State Farm Mut. Auto Ins. Co., 331 F.3d 1122, 1135 (9th Cir. 2003)). “The presumption 27 of access is ‘based on the need for federal courts, although independent—indeed, 28 particularly because they are independent—to have a measure of accountability and for the 1 public to have confidence in the administration of justice.’” Ctr. for Auto Safety v. Chrysler 2 Grp., LLC, 809 F.3d 1092, 1096 (9th Cir. 2016) (quoting United States v. Amodeo, 71 F.3d 3 1044, 1048 (2d Cir. 1995)). 4 A party seeking to seal a judicial record bears the burden of overcoming the strong 5 presumption of access. Foltz, 331 F.3d at 1135. The showing required to meet this burden 6 depends upon whether the documents to be sealed relate to a motion that is “more than 7 tangentially related to the merits of the case.” Ctr. for Auto Safety, 809 F.3d at 1101. In 8 other words, the presumption of public access fully applies to “dispositive pleadings,” such 9 as “motions for summary judgment and related attachments.” Kamakana v. City & Cnty. 10 of Honolulu, 447 F.3d 1172, 1179 (9th Cir. 2006). However, the Ninth Circuit has “carved 11 out an exception to the presumption of access” to judicial records for a “sealed discovery 12 document [attached] to a non-dispositive motion,” such that “the usual presumption of the 13 public’s right of access is rebutted.” Id. at 1179 (citing Foltz, 331 F.3d at 1135). 14 The Ninth Circuit, thus, applies different standards for evaluating requests to seal 15 documents accompanying dispositive motions and those accompanying non-dispositive 16 motions. Kamakana, 447 F.3d at 1179. When the underlying motion is more than 17 tangentially related to the merits (i.e., a dispositive motion), the “compelling reasons” 18 standard applies. Id.; see also Ctr. for Auto Safety, 809 F.3d at 1096–98. “In general, 19 ‘compelling reasons’ sufficient to outweigh the public’s interest in disclosure and justify 20 sealing court records exist when such ‘court files might have become a vehicle for improper 21 purposes,’ such as the use of records to gratify private spite, promote public scandal, 22 circulate libelous statements, or release trade secrets.” Kamakana, 447 F.3d at 1179 23 (quoting Nixon, 435 U.S. at 598). However, when the underlying document is a non- 24 dispositive motion, the “good cause” standard applies, and a district court may issue “any 25 order which justice requires to protect a party or person from annoyance, embarrassment, 26 oppression, or undue burden or expense.” Id. at 1180. 27 II. ANALYSIS 28 A. Procedural Requirements 1 The Court’s Standing Order notes, “[t]he fact that both sides agree to seal a document 2 or that a stipulated protective order was issued is insufficient cause for sealing.” Standing 3 Order § 5.A (“§ 5.A”). “Parties often seek to seal a document only because another party 4 designated the document as sensitive under a protective order . . . [i]n these circumstances, 5 the moving party must first meet and confer with the designating party to determine 6 whether the designating party maintains that any portion of the document must be filed 7 under seal.” Id. Then, “the designating party must file a response to the sealing motion 8 within seven days that satisfies the sealing standard . . . If no response is filed, the Court 9 may order that the document be filed in the public record.” Id. 10 Given that the Motion to Seal is jointly filed by Parties (ECF No. 43), the Court finds 11 Plaintiff—as the party designating the relevant documents as confidential—does not need 12 to file a response to the Motion to Seal within seven days. 13 B. Related Documents More Than Tangentially Related to Merits 14 Parties’ proposed documents to seal are relevant for determining the merits of 15 Defendants’ summary judgment motion (ECF Nos. 41, 43, 44). See Pac. Marine 16 Propellers, Inc. v. Wartsila Def., Inc., No. 17-CV-555-L-NLS, 2018 WL 11457880, at *1 17 (S.D. Cal. Nov. 5, 2018) (“The compelling reasons standard applies to all motions except 18 those that are only ‘tangentially related to the merits of a case’ . . . Defendants’ summary 19 judgment motion is more than tangentially related to the merits”) (citing Kamakana, 447 20 F.3d at 1179). 21 More specifically, Parties move to file the following documents under seal: 22 1. Plaintiff’s Personnel Action Forms (ECF No. 44 at City 49 to City 51, City 23 317); 24 2. Plaintiff’s Disciplinary and Investigative Documents (ECF No. 44 at City 25 95 to City 103, City 146 to City 166, and City 336 to City 339); 26 3. Plaintiff’s Internal Affairs Documents (ECF No. 44 at City 109, City 167, 27 City 170 to City 174, and City 181 to City 191); and 28 1 4. Plaintiff’s Written Reprimands and Counseling Memoranda (ECF No. 44 2 at City 110 to City 111 and City 333 to City 334). 3 These documents are related to Defendants’ motion for partial summary judgment 4 (ECF No. 41) because they are related to determining the merits of Plaintiff’s disputed 5 employment retaliation claims. As such, the Court finds Plaintiff’s motion to seal (ECF 6 No. 43) is subject to the “compelling reasons” standard in Kamakana, 447 F.3d at 1179. 7 C. “Compelling Reasons” 8 Here, Parties move to seal documents accompanying the Motion to Seal on the bases 9 that they are subject to: (1) peace officer personnel record privilege under Section 832.7 of 10 the California Penal Code (Cal. Pen. Code § 832.7); (2) official information privilege, 11 and/or (3) the material protected by third parties’ constitutional right to privacy. 12 Regarding Cal. Pen. Code § 832.7, “federal courts generally should give some 13 weight to privacy rights that are protected by state constitutions or state statutes.” Kelly v. 14 City of San Jose, 114 F.R.D. 653, 656 (N.D. Cal. 1987). Cal. Pen. Code § 832.7 clearly 15 provides that California peace officer personnel records are confidential. San Diego Police 16 Officers Assn. v. City of San Diego Civil Service Comm., 104 Cal.App.4th 275, 287 (2002) 17 (“We conclude section 832.7 provides that peace officer personnel records, as defined in 18 section 832.8, are confidential. Thus, employing agencies may not freely disclose these 19 records at public disciplinary appeal hearings if the affected officer asserts an objection.”). 20 Here, the documents in ECF No. 44 are police officer personnel records and subject 21 to privilege under Cal. Pen.

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Related

Nixon v. Warner Communications, Inc.
435 U.S. 589 (Supreme Court, 1978)
Center for Auto Safety v. Chrysler Group, LLC
809 F.3d 1092 (Ninth Circuit, 2016)
San Diego Police Officers Ass'n v. City of San Diego Civil Service Commission
104 Cal. App. 4th 275 (California Court of Appeal, 2002)
Garrett v. City & County of San Francisco
818 F.2d 1515 (Ninth Circuit, 1987)
Kelly v. City of San Jose
114 F.R.D. 653 (N.D. California, 1987)

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Bluebook (online)
Paul Sonico v. City of Brawley, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/paul-sonico-v-city-of-brawley-et-al-casd-2026.