Major League Baseball Players Association v. Arroyo
- Lewis Liman
- 1:24-cv-03029
- U.S. District Court · Southern District of New York
- 3
In Major League Baseball Players Association v. Arroyo, Judge Liman granted the plaintiff’s requests to file certain exhibits with narrow redactions protecting nonparties’ identifying information.
The ruling affects the Major League Baseball Players Association, the defendants, and nonparties whose names and identifying information appear in the specified exhibits. The exhibits may be filed with narrow redactions.
What happened
In Major League Baseball Players Association v. Arroyo, the plaintiff asked to redact names and identifying information from certain exhibits filed with its request to confirm an arbitration decision. The redacted information concerned nonparties, including professional baseball players, their agents and agencies, and employees of the defendants’ agency.
The court had previously found that the documents were generally available to the public but allowed renewed requests for limited, targeted, and supported redactions. The court concluded that the proposed redactions protected nonparties’ privacy and would not interfere with the public’s ability to understand the court’s decision.
Judge Lewis J. Liman granted the plaintiff’s motions to file certain exhibits with redactions and directed the Clerk of Court to close the related docket entries.
The detailed version
- Major League Baseball Players Association v. Arroyo · No. 1:24-cv-03029
- Lewis Liman
- July 1, 2024
Background
The plaintiff moved under Rule 2(H)(ii) of the court’s Individual Practices in Civil Cases for permission to file certain exhibits with narrowly tailored redactions. The exhibits were filed in connection with the plaintiff’s motion to confirm an arbitration decision and its reply supporting that motion. The defendants took no position on the requests.
The parties had initially sought to file several documents related to the arbitration entirely under seal, meaning unavailable to the public. The court previously ruled that the documents were judicial documents subject to a strong presumption of public access. It denied the initial sealing motions without prejudice to renewed motions seeking limited, targeted, and well-supported redactions.
Court’s Analysis
In the renewed motions, the plaintiff no longer sought to seal the arbitrator’s decision. Instead, it requested narrow redactions in the Notice of Discipline, Notice of Appeal, a hearing transcript concerning the defendants’ motion for a temporary restraining order, and a supplemental letter submitted in connection with that proposed motion.
The requested redactions covered names and identifying information of nonparties, including professional baseball players, their agents and agencies, and employees of the defendants’ agency. The court explained that nonparties have significant privacy interests supporting redaction of identifying information. It also found that the identities had no apparent bearing on the dispute. The court concluded that the redactions would protect those privacy interests while still allowing the public and press to evaluate the basis for the court’s decision.
Disposition
The court concluded that the proposed redactions were narrowly tailored and appropriately balanced public access against nonparties’ privacy interests. Judge Lewis J. Liman granted the plaintiff’s motions to file certain exhibits with redactions, Dkt. Nos. 27 and 31. The Clerk of Court was directed to close those docket entries.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.