Jose Castro Martinez v. Christopher J. Larose, Warden, Otay Mesa Detention Center, et al.
- Proceeding
- district
- Area
- civil
- Panel
- Dana M. Sabraw (author)
Analysis
The court considered Respondents' motion to seal an excerpt of the Petitioner's medical records and sua sponte reviewed the Petitioner's filed medical records. The court granted the motion to seal, ordered the sealing of the Petitioner's medical records, and directed the parties to review the docket for other sensitive information.
| What the court decided | The model |
|---|---|
Granting Respondents' Motion to Seal ECF No. 8“Accordingly, the Court GRANTS Respondents’ Motion to Seal.” | agree with court The court applied the standard that medical privacy constitutes a compelling reason to seal records, overriding the presumptive right of public access. This is a standard application of Ninth Circuit and district court precedent regarding the sealing of medical records. |
Sua sponte sealing of Exhibit B to Petitioner’s Motion for TRO (ECF No. 5-3)“For the same reasons, the Court ORDERS, sua sponte, the sealing of Exhibit B to Petitioner’s motion for temporary restraining order, ECF No. 5-3.” | agree with court The court cited authority that courts may seal medical information sua sponte. Since the document in question was identified as medical records from UCLA Medical Center, the court's action to seal it sua sponte is consistent with the cited precedent and the nature of the document. |
Directing parties to review docket for private or sensitive information“The Court further ORDERS the Parties to review the docket items to determine whether other documents contain private or sensitive information, such that the documents should be withdrawn and refiled with redactions or, alternatively, sealed.” | agree with court The court identified a specific concern regarding third-party birthdates in the docket. Ordering a review to redact or seal such information is a reasonable procedural measure to protect privacy interests and comply with privacy laws. |
The order itself: sound — The order correctly identifies the legal standard for sealing medical records (compelling interest overriding public access) and applies it to the specific facts (medical records filed by both parties). It cites relevant district court precedent. The sua sponte action is supported by the cited authority. The directive to review the docket is a prudent procedural step given the identified privacy concerns.
Opinion
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 JOSE CASTRO MARTINEZ, Case No.: 3:25-cv-03449-DMS-MMP 12 Petitioner, ORDER: 13 v. (1) GRANTING RESPONDENT’S 14 CHRISTOPHER J. LAROSE, Warden, MOTION TO SEAL; Otay Mesa Detention Center, et al., 15 Respondents. (2) SEALING EXHIBIT B to 16 PETITIONER’S MOTION FOR 17 TEMPORARY RESTRAINING ORDER; and 18 19 (3) DIRECTING PARTIES TO REVIEW DOCKET FOR FURTHER 20 PRIVATE OR SENSITIVE 21 INFORMATION 22 [ECF Nos. 5-3, 7, 8] 23 24 On December 10, 2025, Petitioner filed, as Exhibit B to his motion for temporary 25 restraining order, pages of his medical records from UCLA Medical Center. (ECF No. 5- 26 3). On December 11, 2025, Respondents filed an opposition to Petitioner’s petition for 27 writ of habeas corpus and motion for temporary restraining order (“Opposition”). (ECF 28 No. 6). Respondents same-day moved to file under seal and lodged an exhibit in support 1 of their Opposition. (ECF Nos. 7, 8). Specifically, Respondents seek to file under seal an 2 excerpt from Petitioner’s medical records from Otay Mesa Detention Center. (ECF Nos. 3 7, 8). The Court (1) grants Respondent’s motion to file ECF No. 8 under seal and (2) 4 orders, sua sponte, the sealing of Exhibit B to Petitioner’s motion for temporary restraining 5 order, ECF No. 5-3. 6 “There is a presumptive right of public access to court records based upon the 7 common law and the first amendment.” Rashidiasl v. MEP (ESIS/ARCH/CHUBB), No. 8 23-CV-0325-GPC-DEB, 2025 WL 3241124, at *1 (S.D. Cal. Nov. 20, 2025) (citations 9 omitted). “District courts in this circuit have concluded that the need to protect medical 10 privacy qualifies as a compelling reason to seal records.” Id. (citations omitted). “[S]ome 11 courts have gone so far as to seal medical information sua sponte.” Id. (citing San Ramon 12 Reg’l Med. Ctr., Inc. v. Principal Life Ins. Co., No. 10–cv–02258–SBA, 2011 WL 89931, 13 at *1 n.1 (N.D. Cal. Jan. 10, 2011)). Because Respondents’ lodged document is an excerpt 14 from Petitioner’s medical records, the Court finds there are compelling reasons to seal ECF 15 No. 8. Accordingly, the Court GRANTS Respondents’ Motion to Seal. For the same 16 reasons, the Court ORDERS, sua sponte, the sealing of Exhibit B to Petitioner’s motion 17 for temporary restraining order, ECF No. 5-3. The Court DIRECTS the Clerk of Court to 18 seal ECF No. 5-3 (Exhibit B to Petitioner’s TRO Motion) and ECF No. 8. 19 Additionally, the Court is concerned that other docket items, currently publicly 20 available, may also contain private or sensitive information.1 Therefore, the Court further 21 ORDERS the Parties to review the docket items to determine whether other documents 22 contain private or sensitive information, such that the documents should be withdrawn and 23 refiled with redactions or, alternatively, sealed. The Parties shall review the docket items 24 and take any appropriate actions, including but not limited to moving to seal select 25 documents, within fourteen days of entry of this Order. 26 27 1 Specifically, the Court has concerns that several documents reveal the birthdates of third parties. See 28 1 IT IS SO ORDERED. 2 || Dated: December 16, 2025 3 Yn. L4\ Hon. Dana M. Sabraw 4 United States District Judge 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28