San Diego Unified School District v. K.A.
- Proceeding
- district
- Area
- civil
- Panel
- Janis L. Sammartino (author)
Analysis
The parties filed a joint motion to file the administrative record under seal in a FERPA-related civil action. The court denied the motion without prejudice because the parties failed to lodge the proposed sealed document as required by the local electronic filing manual, ordering them to refile by August 28, 2026.
| What the court decided | The model |
|---|---|
Joint Motion to File Administrative Record Under Seal denied without prejudice“Therefore, the Joint Motion is DENIED WITHOUT PREJUDICE. The Parties SHALL REFILE the Motion to Seal with the proposed sealed documents lodged according to the Manual by August 28, 2026.” | agree with court The court correctly applied the local administrative rule requiring that proposed sealed documents be lodged electronically for review before a motion to seal can be granted. The denial without prejudice is procedurally appropriate as it allows the parties to cure the deficiency. The court noted it was 'inclined to grant' the motion, suggesting the substantive merits were likely sufficient, but the procedural requirement was not met. |
The order itself: sound — The order is procedurally sound. It correctly identifies the local rule violation (failure to lodge the document) and provides a clear path for correction (refile by a specific date). The citation to Carmel Unified Sch. Dist. v. Hodges is appropriate for the substantive context, though the decision rests on procedural grounds rather than the merits.
Opinion
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 SAN DIEGO UNIFIED SCHOOL Case No.: 25-CV-2844 JLS (MSB) 12 D ISTRICT, 13 Plaintiff, ORDER DENYING WITHOUT PREJUDICE JOINT MOTION TO 14 vs. FILE ADMINISTRATIVE RECORD 15 K.A., UNDER SEAL 16 Defendant. (ECF No. 12)
17 K.A., 18 Counter-claimant, 19 vs.
20 SAN DIEGO UNIFIED SCHOOL DISTRICT, 21
Counter-defendant. 22 23 24 Presently before the Court is the Parties’ Joint Motion to File Administrative Record 25 Under Seal (“Joint Mot.,” ECF No. 12). The Parties seek to seal the administrative record 26 of the underlying state action under the Family Educational Rights and Privacy Act and 27 California state law. Joint Mot. at 2. While the Court is inclined to grant the Motion, see 28 Carmel Unified Sch. Dist. v. Hodges, No. 23-CV-856-PCP, 2023 WL 9102072, at *1–2 1 || (N.D. Cal. Dec. 21, 2023), the Court cannot at this time as the Parties failed to lodge the 2 ||proposed document to be filed under seal for the Court’s review as required by the 3 Electronic Case Filing Administrative Policies and Procedures Manual.' 4 Therefore, the Joint Motion is DENIED WITHOUT PREJUDICE. The Parties 5 ||SHALL REFILE the Motion to Seal with the proposed sealed documents lodged 6 || according to the Manual by August 28, 2026. 7 IT IS SO ORDERED. 8 || Dated: August 24, 2026 . L . ? pee Janis L. Sammartino 10 United States District Judge 1] 12 13 14 15 16 17 18 19 20 21 22 ' The relevant policy is as follows: “Any document submitted for filing under seal in civil cases must be 23 accompanied by a motion authorizing such filing. In civil cases the motion to seal will be filed as a public 74 document using the appropriate CM/ECF event located under the ‘Sealed Documents’ category. The proposed document to be filed under seal must be lodged electronically using the ‘Sealed Lodged 25 || Proposed Document’ event located under the ‘Sealed Documents’ category. If the motion to seal is granted, the judge will issue an order authorizing the electronic filing by the Clerk’s Office of the lodged 26 || proposed document under seal. If the motion to seal is denied, the document will remain lodged under seal without further consideration absent contrary direction from the Court.” Electronic Case Filing 27 Administrative Policies and Procedures Manual, Sealed and Juvenile Documents (January 16, 2026), 22 https://www.casd.uscourts.gov/_assets/pdf/cmecf/Electronic%20Case%20Filing%20Procedures%20Ma nual.pdf.