3621 v. City of New York
Local 3621, EMS Officers Union, DC-37, AFSCME, AFL-CIO, individually and on behalf of its members, Renae Mascol, and Luis Rodriguez v. City of New York, New York City Fire Department, and Department of Citywide — Administrative Services
- Lewis Liman
- 1:18-cv-04476
- U.S. District Court · Southern District of New York
- 3
In Local 3621 v. City of New York, Judge Liman denied Renae Mascol’s request to keep disciplinary-history discussion in a summary-judgment opinion sealed.
Renae Mascol, whose request to seal discussion of her employment disciplinary history was denied; the information remains subject to public access under this order.
What happened
Local 3621 v. City of New York concerned Renae Mascol’s request to seal parts of a court opinion discussing her employment disciplinary history, including disciplinary allegations and findings. The information appeared in an opinion addressing the defendants’ summary-judgment motion.
The court said materials connected to summary-judgment motions carry a strong presumption of public access and should remain sealed only for the most compelling reasons. The court also noted that the information had already been made public and that Mascol relied on her disciplinary history in arguing that discrimination could be inferred.
Judge Lewis J. Liman ruled that Mascol’s privacy interests did not overcome the presumption of public access. He denied the motion to seal and directed the Clerk of Court to close the motion’s docket entry.
The detailed version
- 3621 v. City of New York · No. 1:18-cv-04476
- Lewis Liman
- Oct. 15, 2025
Background
Renae Mascol moved to seal portions of the court’s September 30, 2025 Opinion and Order that discussed her employment disciplinary history, including underlying disciplinary allegations and findings. That earlier opinion had granted in part and denied in part the defendants’ motion for summary judgment. Mascol noted that the court had previously sealed related information in connection with earlier filings.
Access to Judicial Documents
The court explained that judicial documents—court filings that could influence the court’s exercise of its judicial powers—are generally presumed to be open to the public under both common law and the First Amendment. Materials submitted in connection with summary judgment receive a particularly strong presumption of public access, regardless of how much the court relied on them. Such materials should not remain sealed without the most compelling reasons.
The court distinguished Mascol’s earlier sealing requests because they arose during non-dispositive motions, which receive a weaker presumption of public access. The court also observed that the disciplinary information had already been made public. Although privacy interests of innocent third parties can weigh heavily in the sealing analysis, the court found that Mascol was not a third party and had placed the information at issue by relying on her discipline to support an inference of discrimination.
Ruling
The court determined that any privacy interests were insufficient to overcome the strong presumption of public access. The court therefore denied Mascol’s motion to seal and directed the Clerk of Court to close Docket No. 718. This order addressed sealing only; it did not revisit the merits disposition of the defendants’ summary-judgment motion.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.