Doe v. Columbia University
John Doe v. Columbia University, et al.; John Doe v. Marcus Jeremy Hunter, et al.; John Doe v. Neel H. Kachalia, et al.
- Ho
- 1:23-cv-10393
- U.S. District Court · Southern District of New York
- 4
In John Doe v. Columbia University, Judge Ho granted Columbia’s requests to keep parts of Doe’s reply brief under seal.
John Doe and Columbia University, as well as the parties whose confidential settlement agreement is discussed in the sealed portions of Doe’s reply memorandum.
What happened
In John Doe v. Columbia University, John Doe v. Marcus Jeremy Hunter, and John Doe v. Neel H. Kachalia, Columbia University asked the court to redact parts of Doe’s reply memorandum supporting his request to change the judgment. Doe objected. The cases involve allegations of sexual assault, and the court had previously dismissed them as time-barred.
The court found that the reply memorandum was a court filing connected to a request that could resolve the case, so the public had a strong interest in accessing it. But the court also found that protecting the contents of the parties’ confidential settlement agreement was a sufficient reason to limit public access. The court concluded that Columbia’s proposed redactions were appropriately narrow.
Judge Dale E. Ho granted Columbia’s requests. The court ordered that Doe’s reply memorandum remain under seal in all three cases, while allowing redacted versions to remain available on the public docket.
The detailed version
- Doe v. Columbia University · No. 1:23-cv-10393
- Ho
- Oct. 16, 2025
Background
These three related cases concern allegations of sexual assault involving events that occurred from 2012 to 2014 or 2015, around the time John Doe was an undergraduate student at Columbia University. The opinion states that prior litigation concerning substantially the same events was initiated in 2019 and settled in 2020. In an earlier round of these cases, the court dismissed the actions as time-barred.
Columbia moved to redact portions of Doe’s reply memorandum supporting his motion to alter or amend the judgment under Rule 59(e) of the Federal Rules of Civil Procedure. Doe opposed the requests. The opinion states that the court had previously approved Columbia’s requests to redact information concerning the parties’ confidential settlement agreement.
Court’s Analysis
The court applied the Second Circuit’s three-part framework for sealing or redacting court filings. Under that framework, the court considers whether the material is a judicial document, how strong the public’s right of access is, and whether a countervailing interest justifies restricting access.
The court determined that the reply memorandum was a judicial document because it was filed in connection with a motion seeking to alter or amend the judgment. Because that motion was essentially a request that could resolve the case, the document carried a high presumption of public access. The court nevertheless found that the sensitivity of the contents of the parties’ past settlement agreement justified redaction, for the same reasons the court had given in its earlier sealing order. It also concluded that the proposed redactions were narrowly tailored to protect that interest.
Disposition
Judge Dale E. Ho granted Columbia’s requests. The court ordered that Doe’s reply memorandum remain under seal in each of the three cases. The court stated that redacted versions could be found on the public docket at ECF No. 70 in No. 23 Civ. 10393, ECF No. 38 in No. 23 Civ. 10394, and ECF No. 55 in No. 23 Civ. 10395.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.