Wright v. Ethical Culture Fieldston School

Background

The defendants asked to seal documents supporting their motion to enforce a settlement agreement. The court’s order concerns access to those documents and the scope of proposed redactions.

The plaintiffs argued that the settlement the defendants sought to enforce was an improperly negotiated “aggregate settlement”—a settlement involving multiple claims or parties—that the named plaintiffs had not approved. The defendants proposed redacting, among other information, references to the fact that the settlement discussions concerned a putative class-action lawsuit.

Court’s Analysis

The court applied the strong presumption of public access to documents used to determine litigants’ substantive legal rights. It explained that the presumption is weaker for documents that come before the court only to establish that they are irrelevant.

The court found that the proposed redactions could obscure information relevant to the plaintiffs’ arguments about the settlement. It also found that redacting the fact that the settlement concerned class-action claims was not necessary to keep the settlement terms confidential or to protect third-party privacy interests. The court rejected the defendants’ comparison to redactions previously allowed in another case because those redactions did not include references to a class-action settlement and were less extensive.

Ruling

Judge J. Paul Oetken denied the defendants’ request to seal the documents. The order permits the defendants to propose revised redactions on or before November 27, 2024. It states that information concerning the plaintiffs may not be redacted, nor may information concerning whether the settlement was negotiated as a series of individual settlements or as an aggregate settlement. The order allows redaction of information concerning the terms, identities, or amounts of third-party settlements, as well as information protected by attorney-client privilege.