McConkey v. The Churchill School and Center
- Lewis Liman
- 1:24-cv-06091
- U.S. District Court · Southern District of New York
- 1
In McConkey v. The Churchill School and Center, Judge Liman granted McConkey’s motion to file discovery materials with redactions under seal.
The ruling affects McConkey’s filing and the privacy interests of third parties whose names may appear in the materials.
What happened
In McConkey v. The Churchill School and Center, Plaintiff Dennis McConkey asked to file a document with limited redactions because the defendant had marked transcripts as confidential.
The defendant asked McConkey to redact the names of people who had raised discrimination complaints or allegedly engaged in misconduct. The court noted that public access is less strongly presumed for materials submitted with a discovery motion and that protecting third parties’ privacy can support redaction.
Judge Lewis J. Liman granted the motion to file the material with redactions under seal. The order does not identify the specific document or the particular redactions.
The detailed version
- McConkey v. The Churchill School and Center · No. 1:24-cv-06091
- Lewis Liman
- Dec. 1, 2025
Background
Plaintiff Dennis McConkey, through counsel, asked the court for permission to file a document containing limited redactions. McConkey stated that the defendant had marked the transcripts as confidential. The request concerned a filing in connection with a discovery motion.
Requested Redactions
The defendant asked McConkey to redact the names of individuals who raised discrimination complaints or engaged in purported misconduct. McConkey asked the court to delay ruling for one week so the defendant could submit a letter addressing the proposed redactions.
Court’s Reasoning
The court stated that the presumption of public access is weaker for materials submitted in connection with a discovery motion. It also recognized the privacy interests of third parties, quoting authority that the privacy interests of innocent third parties should weigh heavily in the court’s balancing analysis.
Disposition
Judge Lewis J. Liman granted the motion to file the material with redactions under seal. The brief order does not specify the document at issue or identify the redactions that may be made.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.