John Doe v. Regents of The University of California
- Proceeding
- district
- Area
- civil
- Panel
- Janis L. Sammartino (author)
Analysis
The court reviewed Plaintiff John Doe's oppositions to Defendant's Motions in Limine, which contained unauthorized redactions of the Plaintiff's name. The court struck the oppositions sua sponte and ordered the Plaintiff to re-file them by April 9, 2025, following proper sealing procedures.
| What the court decided | The model |
|---|---|
Striking of Plaintiff's Oppositions to Defendant's Motions in Limine Nos. 1 and 2“Thus, the Court sua sponte STRIKES Plaintiff’s Oppositions to Defendant’s Motions in Limine Nos. 1 and 2 (ECF Nos. 92, 93) pursuant to its inherent authority to manage its docket.” | agree with court The court's decision to strike the filings is supported by its inherent authority to manage the docket and ensure compliance with local rules regarding sealing and redaction. The order cites a prior local order (ECF No. 48) prohibiting sealing without a court order and a subsequent order (ECF No. 85) outlining proper procedures. The unauthorized redaction of the plaintiff's name, while a motion to proceed anonymously is pending, violates these procedures. The remedy of striking the document and allowing re-filing is a standard and appropriate exercise of judicial authority to maintain the integrity of the public record. |
Ordering Plaintiff to re-file Oppositions“Plaintiff SHALL, while following proper sealing procedures, re-file its oppositions to Defendant’s Motions in Limine Nos. 1 and 2 on or before April 9, 2025.” | agree with court The order to re-file is a logical and necessary consequence of striking the defective filings. It provides the plaintiff with an opportunity to cure the procedural defect (unauthorized redaction) by following the correct sealing procedures, thereby preserving the plaintiff's right to be heard on the motions in limine. The deadline is specific and reasonable. |
The order itself: sound — The order is procedurally sound. It correctly identifies the violation (unauthorized redaction in violation of a prior court order and local rules), cites the appropriate source of authority (the court's inherent authority to manage its docket, supported by a recent Ninth Circuit case), and imposes a reasonable and specific remedy (striking the filings and ordering re-filing with proper procedures). The court also appropriately cautions the parties about the narrow tailoring requirement for sealing requests.
How this analysis was made · dispute it
unusual dispositionOpinion
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 JOHN DOE, Case No.: 22-CV-1506 JLS (VET)
12 Plaintiff, ORDER SUA SPONTE STRIKING 13 v. PLAINTIFF’S OPPOSITIONS TO DEFENDANT’S MOTIONS IN 14 REGENTS OF THE UNIVERSITY OF LIMINE NOS. 1 & 2 CALIFORNIA, 15 (ECF Nos. 92, 93) Defendant. 16 17 Presently before the Court are Plaintiff John Doe’s Oppositions to Defendant’s 18 Motions in Limine Nos. 1 and 2. ECF Nos. 92, 93. Throughout the exhibits attached to 19 the Oppositions, Plaintiff redacted, without authority, Plaintiff’s real name. See ECF 20 No. 48 (“No party may file any document under seal, expect [sic] pursuant to a court order 21 that authorizes filing of the document, or portion of the document, under seal.” (emphasis 22 added)). The Court recently made clear that, while Plaintiff’s Motion to Proceed 23 Anonymously remains pending, the Parties are to follow proper sealing procedures for 24 redacting portions of filed documents. ECF No. 85 at 1–2 (outlining the procedures the 25 Parties are expected to utilize). Thus, the Court sua sponte STRIKES Plaintiff’s 26 Oppositions to Defendant’s Motions in Limine Nos. 1 and 2 (ECF Nos. 92, 93) pursuant to 27 its inherent authority to manage its docket. See Cahill v. Insider Inc., No. 24-2199, 28 2025 WL 838264, at *4 (9th Cir. Mar. 18, 2025). 1 The Court recognizes that it did not police the Parties’ persistent redaction of 2 Plaintiffs name throughout this litigation with the careful attention that it deserves. 3 || Nevertheless, it should be apparent that, after sua sponte ordering Plaintiff to file his 4 Motion to Proceed Anonymously on February 20, 2025, the Court is taking the public’s 5 || right of access to the judicial system seriously. The Parties are expected to do the same. 6 Plaintiff SHALL, while following proper sealing procedures, re-file its oppositions 7 ||to Defendant’s Motions in Limine Nos. 1 and 2 on or before April 9, 2025. Plaintiff is 8 cautioned that requests to seal must be narrowly tailored—a party may not seek to seal an 9 || entire document where redaction would suffice. See Apex.AI, Inc. v. Langmead, No. 5:23- 10 || CV-02230-BLF, 2023 WL 4157629, at *1 (N.D. Cal. June 23, 2023). 11 IT IS SO ORDERED. 12 ||Dated: April 7, 2025 jae L. Lo memeaite- 3 on. Janis L. Sammartino United States District Judge 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28