Judge: Lee S. Arian, Case: 22STCV16849, Date: 2025-03-06 Tentative Ruling

Case Number: 22STCV16849    Hearing Date: March 6, 2025    Dept: 27

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT

Legal Standard 

Unless confidentiality is required by law, court records are presumed to be open to the public. (Cal. Rules of Court, rule 2.550(c); NBC Subsidiary (KNBC-TV), Inc. v. Superior Court (1999) 20 Cal.4th 1178, 1199-1200.) Documents may not be filed under seal merely by stipulation; sealing requires a court order based on specific findings. (Cal. Rules of Court, rule 2.551(a); H.B. Fuller Co. v. Doe (2007) 151 Cal.App.4th 879, 888.) 

A party seeking to seal records must establish the following: (1) an overriding interest that overcomes the public’s right of access; (2) the overriding interest supports sealing; (3) a substantial probability that the overriding interest will be prejudiced if the record is not sealed; (4) the proposed sealing is narrowly tailored; and (5) no less restrictive means exist. (CRC 2.550(d)(1)-(5); McGuan v. Endovascular Techs., Inc. (2010) 182 Cal.App.4th 974, 988.) Courts must balance constitutional disclosure requirements with privacy and proprietary interests. (People v. Jackson (2005) 128 Cal.App.4th 1009, 1026-1027.) The decision to seal rests within the Court’s discretion. (Universal City Studios, Inc. v. Superior Court (2003) 110 Cal.App.4th 1273, 1285.) 

Discussion

KFHP seeks to seal the following documents in support of its Motion for Summary Judgment:

1.  Exhibit 1 to the Declaration of Kristen Mussman, which contains confidential business terms of KFHP’s contract with AMN Healthcare, Inc.;

2.  Portions of Exhibit 1 to the Declaration of Latanya Simmons, which contain confidential business and personal information, including negotiated billing rates and Defendant Nicole Linton’s personal health records;

3.  Portions of KFHP’s Motion for Summary Judgment referencing the above documents; and

4.  Portions of KFHP’s Separate Statement of Undisputed Material Facts referencing the above documents.

No opposition was filed, and the Court finds that Defendant has established good cause to seal the aforementioned documents based on the following considerations:

The protection of confidential business agreements and proprietary financial information constitutes an overriding interest that justifies sealing under Rule 2.550(d). Courts have recognized that disclosure of such commercially sensitive information can harm a party’s competitive standing. (McGuan v. Endovascular Techs., Inc. (2010) 182 Cal.App.4th 974, 988-989; Universal City Studios, Inc. v. Superior Court (2003) 110 Cal.App.4th 1273, 1283.)

Here, Exhibit 1 to the Mussman Declaration contains detailed contractual terms, including negotiated rates and internal business strategies related to KFHP’s staffing of temporary healthcare workers. Public disclosure of these terms would undermine KFHP’s ability to negotiate future contracts and maintain competitive pricing. Similarly, the redacted portions of Exhibit 1 to the Simmons Declaration contain KFHP’s internal staffing agreements and financial arrangements, the disclosure of which could harm its business operations.

The Linton File, referenced in Exhibit 1 to the Simmons Declaration, also includes personal medical and identification information related to Defendant Nicole Linton. The California Constitution and case law recognize an individual’s right to privacy in medical records. (Vinson v. Superior Court (1987) 43 Cal.3d 833, 841; People v. Jackson (2005) 128 Cal.App.4th 1009, 1028.)

Failure to seal the requested records would likely result in harm to KFHP’s competitive interests and Ms. Linton’s privacy rights. The disclosure of negotiated business agreements could place KFHP at a disadvantage in future contract negotiations, and the exposure of sensitive health records would violate established privacy protections.

KFHP has demonstrated that its sealing request is narrowly tailored. It does not seek to seal entire filings but only the specific portions containing sensitive business or medical information. KFHP has also filed redacted versions of the documents to ensure public access to non-confidential portions of the filings.

Furthermore, given the nature of the confidential business and medical information at issue, there are no less restrictive means to protect the information other than sealing the specified portions of the records.

Accordingly, Defendant’s motion to seal is granted.

Parties who intend to submit on this tentative must send an email to the Court at SSCDEPT27@lacourt.org indicating intention to submit on the tentative as directed by the instructions provided on the court’s website at www.lacourt.org.  Please be advised that if you submit on the tentative and elect not to appear at the hearing, the opposing party may nevertheless appear at the hearing and argue the matter.  Unless you receive a submission from all other parties in the matter, you should assume that others might appear at the hearing to argue.  If the Court does not receive emails from the parties indicating submission on this tentative ruling and there are no appearances at the hearing, the Court may, at its discretion, adopt the tentative as the final order or place the motion off calendar.