Hui v. Federal Reserve Bank of New York

Background

Qiang Jay Hui filed this employment-related case against the Federal Reserve Bank of New York through attorneys on September 6, 2024. He had received a notice from the Equal Employment Opportunity Commission allowing him to sue. Hui later filed an amended complaint, and the defendant answered. The parties engaged in discovery, informed the court that the case had settled, and filed a stipulation of voluntary dismissal on April 16, 2025.

On April 30, 2025, Hui filed a motion without a lawyer asking the court to seal the entire case. He cited severe reputational damage and claimed that public access had caused deep personal and family financial difficulty. He also said that his name had appeared in public search results and had been indexed by more than ten legal-case publication websites.

Legal standard

The court described a strong general presumption that judicial documents—court filings relevant to the court’s work and useful in the legal process—should be available to the public. A person seeking to seal records must provide specific facts showing that sealing is essential to protect a higher value and is narrowly tailored to that purpose. Sealing an entire case file is a last resort.

The court applied a three-step analysis: whether the material is a judicial document, how much weight the public-access presumption carries, and whether competing interests justify restricting access.

Discussion

The court found that the first step was satisfied because Hui sought to seal the entire case file, including the complaint and amended complaint. The court said that a complaint is plainly a judicial document because it begins the case and helps the public understand the court’s actions. The requested sealing also covered everything about the case, including court decisions, so the public-access presumption had especially substantial weight.

The court rejected Hui’s privacy and reputational concerns as a basis for sealing the entire case. It stated that the alleged harms were not different from the consequences that any person bringing a public lawsuit may face. The court also noted that Hui had taken part in several public steps in the case, including seeking the notice allowing suit, filing and amending his complaint, addressing a proposed dismissal motion, and participating in discovery.

Finally, the court found that the case had been public for almost nine months and that sealing it would not remove information already stored on outside websites and databases. The court also could not, in this proceeding, order others not to use information that was already public.

Disposition

Because Hui did not overcome the presumption of public access, Judge Gregory H. Woods denied his motion to seal the case in its entirety. The order did not decide the merits of the underlying claims.