Grove Fresh Distributors, Inc. v. Everfresh Juice Co.
United States Court of Appeals for the Seventh Circuit
24 F.3d 893 (7th Cir. 1994)
Grove Fresh (plaintiff) sued Everfresh and other orange juice companies (defendants) for mislabeling and adulterating juice, obtaining a protective order over confidential discovery in one case and a full seal on the court file in a related case. A group of consumers pursuing their own fraud claims sought to intervene and modify the protective order to reuse the discovery, and were denied on lack-of-standing grounds; a coalition of journalists separately sought access to the sealed materials and were told they had a right to access but would have to wait until the litigation concluded. Both groups appealed the denial or delay of access.
Whether a third party may challenge a protective order or court seal through intervention under Rule 24, and if so, what standard governs their access.