FLORES v. CITIBANK, N.A.
- Laura Swain
- 1:24-cv-03665
- U.S. District Court · Southern District of New York
- 2
In Flores v. Citibank, Judge Swain denied Flores’s motion to seal the case and remove it from online sources.
Valerie Flores, who sought to seal the case and remove its information from online sources; Citibank, N.A., the defendant, and the public docket were also affected by the request.
What happened
In FLORES v. CITIBANK, N.A., the court had previously dismissed Valerie Flores’s case for lack of subject matter jurisdiction and gave her 30 days to file an amended complaint. She did not do so, and the court entered a judgment dismissing the action. Her appeal of that dismissal remains pending.
Flores later asked the court to seal the case, all documents, and the case caption, and to remove information about the case from legal websites and search engines. She cited job-related reasons and other concerns. The court noted that the case had been publicly available on its docket since May 13, 2024.
Judge Laura Taylor Swain denied the motion. She ruled that Flores’s concerns had no legal relevance after the case and filings had been publicly available for that period, and noted that the court could not remove information already collected by private internet platforms. The court also denied fee-free status for any appeal from this order.
The detailed version
- FLORES v. CITIBANK, N.A. · No. 1:24-cv-03665
- Laura Swain
- May 30, 2025
Background
The court had dismissed this action for lack of subject matter jurisdiction in an order dated August 19, 2024, and entered August 22, 2024. That order gave Valerie Flores 30 days to file an amended complaint. Flores did not file one. The court then entered a judgment on November 8, 2024, dismissing the action for lack of subject matter jurisdiction. Flores appealed that dismissal, and the appeal was pending in the United States Court of Appeals for the Second Circuit when the court decided this motion.
Motion to Seal and Remove Online Information
On May 2, 2025, Flores moved to seal the case caption, the entire case, and all documents, and asked the court to remove the case from legal websites and search engines. She stated that the request was based on various job-related reasons and other factors. The court observed that the action had been publicly available on its electronic docket since May 13, 2024, after the case was transferred from the District of Columbia. It concluded that any concerns arising from the filing or the information in the court documents had no legal relevance at that point because the case had already been public for that period. The court also explained that it lacked authority to remove information about the case that private internet platforms had already gathered.
Ruling
The court denied Flores’s motion. It also certified under 28 U.S.C. § 1915(a)(3) that an appeal from this order would not be taken in good faith and denied fee-free status for purposes of an appeal. The order did not change the earlier dismissal of the action or resolve Flores’s pending appeal from that dismissal.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.