Flores v. The City of New York and National Railroad Passenger Corporation…

Background

Plaintiffs and National Railroad Passenger Corporation, doing business as Amtrak, asked the court to seal portions of Plaintiffs’ motion seeking approval of their settlement with Amtrak and portions of Judge Abrams’ April 12, 2025 memorandum opinion and order that referred to the settlement’s financial terms. The requested redactions covered the gross settlement amount, individual distribution amounts, and attorneys’ fees.

A settlement conference occurred on July 1, 2025. Plaintiffs and Amtrak accepted the court’s mediator proposal to resolve Plaintiffs’ claims against Amtrak. Plaintiffs did not settle with the City of New York, and the case continued against the City. The opinion states that Judge Abrams later granted the City’s motion for summary judgment in its entirety.

Judge Abrams directed the settling parties to justify their request to seal under Second Circuit law. The parties publicly filed proposed redacted versions and filed unredacted versions under seal.

Legal standard

Court filings connected to the court’s work are generally subject to a presumption of public access. A party seeking to seal such material bears the burden of showing that sealing is proper. The court first determines whether the material is a “judicial document,” meaning a filed item relevant and useful to the judicial process. If it is, the court determines the weight of the public-access presumption and balances that presumption against competing interests, including privacy.

The public and press also have a qualified First Amendment right to access certain court records. Restrictions must be supported by specific findings showing that closure is necessary to protect higher values and is narrowly tailored to serve that interest.

Court’s analysis

The court held that Plaintiffs’ settlement-approval motion and Judge Abrams’ April 12, 2025 order were judicial documents. It also stated that documents submitted with a motion to approve a settlement receive a strong presumption of public access.

The parties’ agreement that the settlement would remain confidential was not, standing alone, enough to overcome that presumption. However, the court found that the particular circumstances of this case justified protecting legitimate privacy interests. The court considered the settlement amount and noted that other courts had allowed limited redaction of settlement amounts in cases involving court approval of settlements for infants.

The court concluded that the relevant privacy interests outweighed the public-access presumption under both common law and the First Amendment. It further found that the proposed redactions were narrowly tailored.

Disposition

Judge Aaron granted the Joint Letter Motion. The order permitted limited redaction of the settlement’s financial information from the settlement-approval motion and the April 12, 2025 memorandum opinion and order.