Doherty v. Bristol-Myers Squibb Co.
- Garnett
- 1:24-cv-06628
- U.S. District Court · Southern District of New York
- 3
In Doherty v. Bristol-Myers Squibb, Judge Garnett granted defendants’ request to seal and redact three commercially sensitive exhibits.
The ruling affects the Bristol-Myers Squibb defendants, State Street, Athene, the plaintiffs, and the public’s access to the three exhibits. The exhibits will remain under seal with redacted versions filed publicly.
What happened
In Doherty v. Bristol-Myers Squibb Co., the Bristol-Myers Squibb defendants asked to keep three exhibits under seal and file redacted versions publicly. The exhibits were an independent fiduciary agreement and two group annuity contracts.
The defendants argued that the documents contained confidential pricing, financial, and business information whose disclosure could harm their negotiations and competitive position. They also cited privacy interests involving Athene, which was not a party to the case. The plaintiffs opposed the request, while State Street did not oppose it.
Judge Margaret M. Garnett granted the request. She found that the defendants’ interest in protecting competitively sensitive information outweighed the presumption of public access and directed the Clerk of Court to terminate docket entry 49.
The detailed version
- Doherty v. Bristol-Myers Squibb Co. · No. 1:24-cv-06628
- Garnett
- Sept. 29, 2025
Background
The Bristol-Myers Squibb defendants asked for permission to file three exhibits under seal and in redacted form on the public docket: (1) an independent fiduciary agreement between the Bristol-Myers Squibb Company Pension Committee and State Street Global Advisors Trust Company; and (2) two group annuity contracts between Bristol-Myers Squibb Co. and Athene Annuity & Life Assurance Company of New York and Athene Annuity and Life Company of Iowa.
The defendants argued that the exhibits contained proprietary, commercially sensitive, and confidential business information, including financial terms and pricing information. They asserted that disclosure could harm their business interests, State Street’s interests, and Athene’s interests; impair negotiations with third parties; and place the defendants at a competitive disadvantage. They also relied on confidentiality provisions in the annuity contracts and on Athene’s privacy interests. The plaintiffs opposed the motion. State Street did not oppose it.
Court’s Analysis
The court recognized a common-law presumption favoring public access to judicial documents. It also noted that courts in the district routinely seal documents to protect confidential or competitively sensitive business information. After examining the documents and considering the defendants’ representations about their competitive sensitivity, the court concluded that the defendants’ interest in filing them under seal outweighed the presumption of public access.
Ruling
Judge Margaret M. Garnett granted the request to file Exhibits B, C, and D under seal and in redacted form on the public docket. The court directed the Clerk of Court to terminate docket entry 49.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.