Haralson v. Tile Shop, LLC, The
- Dulce Foster
- 0:23-cv-03214
- U.S. District Court · District of Minnesota
- 4
In Haralson v. Tile Shop, LLC, Magistrate Judge Foster granted the parties' joint motion to keep most disputed court documents sealed, finding that confidential business and personal information in those documents outweighs the public's presumptive right of access, while ordering four other documents to be unsealed.
Parties in this employment lawsuit (Cheri Haralson and The Tile Shop, LLC) and any third parties whose names, addresses, or other personal information appear in the sealed documents. Members of the public or press who might seek access to these court filings are also affected, as most documents will remain sealed.
What happened
In Haralson v. Tile Shop, LLC (Case No. 23-cv-3214), plaintiff Cheri Haralson sued defendant The Tile Shop, LLC, and multiple exhibits were filed under seal in connection with The Tile Shop's pending motion for summary judgment. The parties jointly asked the court to keep some of those documents sealed and to unseal others. The dispute centered on whether the public's general right to access court records was outweighed by legitimate interests in keeping certain business and personal information private.
The court applied the legal standard that balances the public's common-law right to access judicial records against the legitimate interests served by keeping documents confidential. The court noted that it did not matter which of two possible legal tests applied — the stricter 'compelling reason' standard or the more lenient 'countervailing reason' standard — because the result would be the same either way. The court also rejected the argument that simply labeling documents 'confidential' during the pretrial exchange of information (known as discovery) is enough by itself to justify sealing them from public view.
Magistrate Judge Foster granted the joint motion in part. After reviewing the documents individually, the court found that the documents at ECF Nos. 89 through 89-6 contain sensitive customer information, personnel records, and other confidential business data belonging to The Tile Shop and third parties — interests the court found sufficient to justify keeping those documents sealed. The four documents at ECF Nos. 89-7 through 89-10, which the parties agreed could be made public, were ordered unsealed. The court also noted that this ruling does not bind the district judge when ruling on the summary judgment motion or at trial.
The detailed version
Case: Haralson v. Tile Shop, LLC, No. 23-cv-3214 (JWB/DJF), U.S. District Court, District of Minnesota. Decided: July 30, 2025. Judge: Magistrate Judge Dulce J. Foster.
Background
Plaintiff Cheri Haralson filed suit against The Tile Shop, LLC. In connection with The Tile Shop's pending Motion for Summary Judgment (a motion asking the court to rule in its favor without a trial, ECF No. 67), Haralson filed multiple exhibits under seal (ECF Nos. 89 to 89-1) and filed statements indicating that redacting those documents was impractical because The Tile Shop had designated each as 'confidential' during discovery (the pretrial process in which parties exchange information). The parties filed a Joint Motion for Continued Sealing (ECF No. 98), agreeing that ECF Nos. 89-7 through 89-10 could be unsealed but that ECF Nos. 89 through 89-6 should remain sealed due to confidential business information.
Legal Standard
The court recognized the common-law right of public access to judicial records, citing IDT Corp. v. eBay, 709 F.3d 1220 (8th Cir. 2013), and Nixon v. Warner Commc'ns, Inc., 435 U.S. 589 (1978). This right is not absolute. When documents play a material role in the exercise of Article III judicial power (the constitutional authority of federal courts to decide cases), a party seeking to seal them must show 'compelling reasons.' When documents play a lesser role, the presumption of access can be overcome by any adequate 'countervailing reason.' Cajune v. Indep. Sch. Dist. 194, 105 F.4th 1070 (8th Cir. 2024); Flynt v. Lombardi, 885 F.3d 508 (8th Cir. 2018).
Analysis
Because The Tile Shop's summary judgment motion remains pending, the court could not yet determine whether the sealed documents would play a material role in the exercise of judicial power. However, the court found the distinction immaterial because its conclusion was the same under either standard.
As to ECF Nos. 89-7 through 89-10: the parties agreed these could be unsealed, and the court, after its own review, agreed and ordered them unsealed.
As to ECF Nos. 89 through 89-6: the parties sought continued sealing on the ground that The Tile Shop had designated them confidential during discovery. The court explicitly rejected that rationale, noting that a confidentiality designation in discovery is not dispositive of whether a document should be sealed in the public court docket. Nevertheless, after independently reviewing each document, the court found they actually do contain sensitive information — including customer information, sensitive business information, and names, addresses, or other personnel information of individuals with legitimate privacy interests. The court found these interests constitute compelling reasons (and, at minimum, adequate countervailing reasons) to outweigh the public interest in access.
Important Caveat
The court noted in a footnote that this sealing ruling has no intended preclusive effect on how the district judge (as opposed to the magistrate judge) may handle the documents in deciding the summary judgment motion or at trial.
Disposition
The Joint Motion for Continued Sealing (ECF No. 98) was GRANTED. ECF Nos. 89, 89-1, 89-2, 89-3, 89-4, 89-5, and 89-6 are to remain under seal. ECF Nos. 89-7, 89-8, 89-9, and 89-10 are to be unsealed.
Reviewer note from the AI+
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.