Lucas v. Hartford Life and Accident Insurance Company

Background The parties jointly requested permission for Hartford Life and Accident Insurance Company to file non-redacted materials under seal for the court’s review in connection with Hartford’s motion for summary judgment. The requested materials included a 1,027-page administrative record, surveillance video, and an email containing a link to Lucas’s appeal materials, which totaled 221 pages. The parties disputed whether the email and linked documents were part of the administrative record, so they discussed them separately.

Reasons Offered for Sealing The parties argued that the materials contained information about Lucas’s medical conditions, diagnoses, and treatment; personally identifying information such as a Social Security number, date of birth, and home address; and surveillance footage showing people other than Lucas. They argued that redacting the large record would be extremely burdensome and that filing the materials publicly would create significant privacy concerns. They requested sealing the materials rather than filing redacted versions.

Ruling Judge Valerie Caproni granted the application in part. The court permitted Exhibits A, B, C, and E of the Lunemann Declaration, Docket 71, to be filed under seal. The court stated that Exhibit D, labeled HARTFORD 001028, did not appear to contain sensitive information. Hartford therefore must file Exhibit D publicly or explain in greater detail why it should be filed under seal. The order addressed only the sealing request and did not decide the underlying insurance dispute or the summary-judgment motion.