Sabic-El-Rayess v. Teachers College

Background

Teachers College asked to file exhibits supporting its motion for summary judgment under seal. The request covered internal policy documents, confidential departmental-meeting minutes, communications from a non-party student, faculty salary-step schedules, a letter of recommendation describing internal department discussions, and an employment agreement involving a non-party faculty member. Teachers College also identified documents produced by the plaintiff and labeled confidential, as well as a document produced by Teachers College that the plaintiff asked to keep under seal. The letter states that the plaintiff confirmed that those documents should be filed under seal and was aware that a separate explanation would be required under the court’s local rule.

Sealing request

The letter described the three-part sealing analysis: whether a filing is a judicial document subject to public access, the strength of the public-access presumption, and whether competing interests—such as privacy—outweigh that presumption. Teachers College argued that the documents were not publicly available and generally had little relevance or public interest. It also argued that privacy interests favored sealing the student communications and the non-party faculty member’s employment agreement. For Exhibit D127, however, the letter states that the privacy interests did not outweigh the public-access interest, while still requesting that the exhibit be filed under seal.

Ruling

The court granted the motion to file the materials under seal temporarily. It stated that it would assess whether to keep the materials sealed or redact them when deciding the underlying motions. The court did not make a final ruling on continued sealing and did not rule on the merits of the underlying case. Judge Jesse M. Furman directed the Clerk of Court to terminate ECF No. 161.