Loomis Sayles Trust Company LLC v. Citigroup Global Markets Inc
- Lorna Schofield
- 1:22-cv-06706
- U.S. District Court · Southern District of New York
- 2
In Loomis Sayles Trust Co. v. Citigroup Global Markets, Judge Schofield partly granted and partly denied requests to seal court filings.
Citigroup Global Markets Inc., Loomis Sayles Trust Company, LLC, Loomis, Sayles & Company L.P., Citadel Securities LLC, and the public’s access to the summary-judgment filings.
What happened
In Loomis Sayles Trust Company, LLC v. Citigroup Global Markets Inc., Citigroup asked to seal filings supporting its summary-judgment motion, including confidential business information and client financial-account information. Loomis Sayles Trust Company, Loomis, Sayles & Company L.P., and Citadel Securities LLC also sought sealing of documents or information they had designated confidential.
The court said summary-judgment filings are generally available to the public, although specific confidential business or personal information may be protected. It allowed narrow redactions but rejected requests to seal entire documents or broader surrounding information.
Judge Lorna G. Schofield granted in part and denied in part the sealing applications at docket numbers 120, 126, 131, 137, and 142, without prejudice to renewal. The court ordered the parties to file redacted documents or renewed motions by August 29, 2024, and directed the Clerk to close those motions.
The detailed version
- Loomis Sayles Trust Company LLC v. Citigroup Global Markets Inc · No. 1:22-cv-06706
- Lorna Schofield
- Aug. 15, 2024
Background
Citigroup Global Markets Inc. asked for permission to file under seal unredacted versions of its summary-judgment memorandum, Local Rule 56.1 statement, and supporting exhibits. The materials included information designated confidential or attorneys-eyes-only by Loomis Sayles Trust Company, LLC, Loomis, Sayles & Company L.P., and Citadel Securities LLC. They also included two trade confirmations identifying Loomis clients and those clients’ financial-account information.
The opinion states that Loomis, Sayles & Company L.P. and Citadel Securities LLC joined the applications to seal various documents. Citigroup took no position on whether the information legally qualified for sealing and said it filed the materials under seal because of the confidentiality designations.
Court’s Analysis
The court explained that court documents filed in connection with a summary-judgment motion are judicial documents subject to a strong presumption of public access under both the common law and the First Amendment. A court may protect confidential business or personal information only when specific findings show that sealing is necessary to protect a higher value and is narrowly tailored to that purpose.
The court found that proposed redactions of specific confidential business and personal information were narrowly tailored to protect against competitive or personal harm. It concluded, however, that the parties’ justifications were insufficient to support sealing entire documents or broader background descriptions and surrounding information.
Disposition
Judge Lorna G. Schofield granted in part and denied in part the applications to seal at Docket Nos. 120, 126, 131, 137, and 142, without prejudice to renewal. The applications were granted to the extent the movants proposed specific redactions and denied to the extent they sought to seal entire documents. Documents already filed under seal were allowed to remain sealed at that time.
By August 29, 2024, the movants were required either to file publicly available versions containing the permitted specific redactions and renewed motions identifying proposed redactions in the remaining documents, or to file unredacted versions on the public docket. The Clerk was directed to close the five sealing motions.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.