Toyota Motor Sales v. Reavis, a companion case to a still-ongoing appeal of a major products-liability judgment, affirmed the denial of Toyota’s motion to seal certain trial exhibits. After reviewing Toyota’s case for confidentiality, the Fifth Court then turned to available less-restrictive means, holding: “Beyond Toyota’s blanket assertions that a total seal is necessary and redaction would be meaningless, Toyota did not offer any additional testimony or evidence regarding whether the Toyota documents could be redacted or otherwise altered while still protecting its interest. Toyota also contends on appeal that it showed sealing was the least restrictive means to protect its interest here because it sought to seal ‘just four exhibits from a trial involving over 900 exhibits and [covering] pages of closed-courtroom testimony from more than 3,200 pages of trial
transcripts.’ This argument misses the point. Rule 76a imposes strict requirements to obtain a sealing order, and parties are not rewarded with a sealing order simply because they ask the court to only seal a few exhibits or a small amount of testimony. No matter how many exhibits a party seeks to seal, that party must still meet the
requirements of the rule.” No. 05-19-00284-CV (Feb. 4, 2021) (mem. op.).

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