Kovats v. Hartford Life and Accident Insurance Company

Background

The case concerns review of a denial of long-term disability benefits under a group insurance plan governed by the Employee Retirement Income Security Act of 1974 (ERISA). In preparation for the parties’ upcoming motions for judgment as a matter of law, the parties expected to cite and rely on Thomas Kovats’s 2,258-page administrative record. Kovats filed an administrative motion asking the court to place that record under seal. Hartford Life and Accident Insurance Company did not oppose the motion.

The administrative record contains extensive private medical information, including information the parties stated was not relevant to the action. The motion sought to seal the administrative record, not information cited in the parties’ briefs or in the court’s opinions.

Legal standard

The court applied the “compelling reasons” standard because the administrative record was more than tangentially related to the underlying claim. Under that standard, a party seeking to seal judicial records connected to a dispositive motion must identify compelling reasons, supported by specific facts, that outweigh the public’s strong interest in access to court records.

Analysis and ruling

The court found that the administrative record consisted of highly sensitive and confidential medical records and documents. It also found that the public interest in disclosure was low because information in the claim file relevant to the merits had not been sealed. The court concluded that the information’s sensitive nature and intended confidentiality satisfied the compelling-reasons standard.

The court therefore granted the motion to seal the administrative record. The order addressed access to the record and did not decide the underlying dispute over Kovats’s eligibility for long-term disability benefits.