Inguanzo v. Housing & Services, Inc.
- Edgardo Ramos
- 1:12-cv-08212
- U.S. District Court · Southern District of New York
- 3
Inguanzo v. Housing & Services, Judge Ramos denied Inguanzo’s motion to seal case records and prevent republication.
Marian M. Inguanzo’s request for sealing, redaction, and a publication restriction was denied. The case records were not sealed under this order, and the court did not restrict their publication or republication.
What happened
In Inguanzo v. Housing & Services, Inc., Marian Inguanzo asked the court to seal the entire case record or redact personal information, nearly 10 years after the case ended. Her earlier discrimination and retaliation claims had been resolved against her on summary judgment, and the appeals court affirmed that decision.
The court said people involved in lawsuits do not have a general right to keep court records private. Inguanzo did not show that sealing was necessary to protect an important value or that her request was narrowly limited; instead, she sought to seal the full docket and related filings. The court also said it could not prevent publication of information that had already become public.
Judge Edgardo Ramos denied the motion and directed the Clerk of Court to terminate it. The opinion does not order sealing, redaction, or a restriction on publishing the case contents.
The detailed version
- Inguanzo v. Housing & Services, Inc. · No. 1:12-cv-08212
- Edgardo Ramos
- Aug. 8, 2025
Background
Marian M. Inguanzo filed the underlying action in 2012 against Housing & Services, Inc., Kristi Kimmerle-Cilenti, individually, and Derrick Horton, individually. She asserted claims under Title VII of the Civil Rights Act of 1964 and the New York City Human Rights Law, alleging discrimination based on gender, race, and national origin, along with retaliation related to her discrimination complaints.
The defendants moved for summary judgment, which is a request for judgment without a trial when the moving party claims there is no genuine dispute requiring a trial. On September 19, 2014, the court granted that motion in its entirety and directed the Clerk of Court to close the case. Inguanzo appealed, and the Second Circuit affirmed the decision on November 30, 2015.
Motion to Seal
On July 10, 2025, Inguanzo moved under Federal Rule of Civil Procedure 5.2 to seal the case records in full. Alternatively, she asked the court to redact all personally identifying information. She also asked for an order preventing publication or republication of the case contents, stating that these measures would protect her privacy and prevent further harm from continued online exposure.
Court’s Analysis
The court applied the presumption that judicial documents should be accessible to the public. It explained that participants in judicial proceedings do not have a general right to privacy. To overcome public access, a party seeking sealing must show that sealing is essential to preserve a higher value, such as the privacy of innocent third parties or law-enforcement interests, and that the requested sealing is narrowly tailored to protect that value.
The court found that Inguanzo had not made those showings. Her request to seal the full case docket and associated filings was overly broad. The court also rejected her request to prevent publication or republication, citing the principle that a court cannot make information private after it has already become public.
Disposition
The motion is DENIED. The court did not order the case sealed, did not order the requested redactions, and did not issue an order preventing publication or republication of the case contents. The Clerk of Court was directed to terminate the motion, docket entry 41.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.