Major League Baseball Players Association v. Arroyo

Background

The Major League Baseball Players Association (MLBPA) brought this action under the Federal Arbitration Act and Section 301 of the Labor Management Relations Act to confirm an arbitration award against William Arroyo, Noah Assad, and Jonathan Miranda. The opinion states that Arroyo was a certified general agent with Rimas Sports and that Assad and Miranda were senior executives of Rimas Sports.

According to the complaint, the MLBPA issued the defendants a Notice of Discipline on April 10, 2024, alleging serious violations of MLBPA regulations, including rules concerning inducements, unlawful recruiters, and cooperation with investigations. The notice revoked Arroyo’s certification and denied certification to Assad and Miranda. The opinion also states that Arbitrator Michael Gottesman denied the defendants’ request for a temporary restraining order staying the discipline while they appealed.

The MLBPA asked to file the Notice of Discipline, the arbitrator’s Decision, and parts of the parties’ submissions under seal. The defendants filed a motion that incorporated the MLBPA’s request and sought similar relief, including sealing their Notice of Appeal. The requests also sought redaction of future quotations or specific findings from the arbitration materials and blanket sealing of future filings containing materials submitted in the arbitration.

Court’s Analysis

The court applied the three-step test used for sealing court records: whether the materials are judicial documents, the strength of the public-access presumption, and whether interests favoring secrecy outweigh that presumption.

The court determined that the Notice of Discipline, the arbitrator’s Decision, the Notice of Appeal, and papers submitted with the motion to confirm the arbitration award were judicial documents. They were relevant to the court’s decision on whether to confirm the award. The court explained that filings supporting a motion to confirm an arbitration award receive the highest level of public-access protection because confirmation can turn the award into a court judgment resolving the parties’ rights.

The court rejected reliance solely on the MLBPA regulations’ confidentiality provisions. It explained that a private organization’s rules generally cannot overcome the public’s interest in access to documents filed in a federal court proceeding. The court also noted that the regulations allowed the MLBPA to disclose aspects of the arbitration when it considered disclosure necessary to administer the regulations or represent players.

The court found that much of the arbitrator’s Decision concerned the standards for a stay, the parties’ arguments, and the arbitrator’s conclusions, rather than highly private facts. It also observed that the complaint and public filings had already disclosed portions of the alleged conduct and discipline. Although the Notice of Discipline and Notice of Appeal referred to other people and included factual material, the parties had not shown specifically which portions implicated privacy interests or otherwise justified sealing.

The court further held that it could not approve a blanket request to seal all future arbitration materials. Under governing precedent and the court’s individual practices, sealing requires an individual document review and specific findings on the record that sealing is necessary to protect interests that outweigh public access.

Disposition

The court denied the motions to seal without prejudice to renewed motions filed by June 28, 2024. The court directed that any renewed requests be limited, targeted, and properly supported. It stated that if no renewed motions were filed by that date, the court would make the Notice of Discipline, the arbitrator’s Decision, and the Notice of Appeal public. The court also directed the Clerk of Court to close Docket Nos. 15 and 23.