Dalla-Longa v. Magnetar Capital LLC
- Lorna Schofield
- 1:19-cv-11246
- U.S. District Court · Southern District of New York
- 3
In Dalla-Longa v. Magnetar Capital LLC, Judge Schofield denied Magnetar’s request to seal the arbitration-vacatur petition and exhibits, while allowing proposed redactions.
Magnetar Capital LLC’s request to keep the petition and related materials under seal was denied, while Magnetar was permitted to propose redactions to confidential information.
What happened
In Dalla-Longa v. Magnetar Capital LLC, Damian Dalla-Longa filed a petition asking the court to vacate an arbitration award. Magnetar Capital asked the court to seal the petition, its exhibits, and any other documents filed in the case, citing a confidentiality agreement and confidential financial and business information.
The court explained that a petition to vacate an arbitration award is a court document covered by the public’s presumptive right of access. A confidentiality agreement alone did not show that sealing was necessary, although the court recognized that access may be limited to protect important interests.
Judge Lorna G. Schofield denied Magnetar’s sealing request. She ordered Magnetar to email proposed redactions to the petition by December 17, 2019, and directed the clerk to remove the petition from the docket.
The detailed version
- Dalla-Longa v. Magnetar Capital LLC · No. 1:19-cv-11246
- Lorna Schofield
- Dec. 12, 2019
Background
Damian Dalla-Longa was the petitioner, and Magnetar Capital LLC was the respondent. Dalla-Longa filed a petition to vacate an arbitration award. By a letter dated December 11, 2019, Magnetar asked the court to seal the petition, its exhibits, and “any other documents to be filed in the case.”
Magnetar relied on an agreement that Dalla-Longa allegedly entered when he was hired. The agreement required confidentiality concerning information about the dispute, mediation, arbitration proceedings, settlement, and arbitration award, subject to stated exceptions. Magnetar also identified specific financial and business information that it said was confidential and appeared in the petition.
Legal standard
The court applied the common-law right of public access to judicial documents. Under the cited standard, sealing requires specific findings showing that closure is essential to protect a higher value and is narrowly tailored to that purpose. The court also noted that the right of access is not absolute and must be balanced against competing considerations.
The court cited decisions holding that petitions to vacate arbitration awards are judicial documents to which the presumption of access applies. It also cited decisions explaining that the existence of a confidentiality agreement, by itself, does not establish that sealing is necessary. The court noted that the parties’ ability to keep private arbitration undertakings confidential changes when a party asks a federal court to enforce or vacate the resulting arbitration award.
Ruling
The court denied Magnetar’s request to seal the petition, its exhibits, and any other documents to be filed in the case. The court further ordered Magnetar to email proposed redactions to the petition to vacate the arbitration award by December 17, 2019, under the court’s Individual Rules. The clerk was respectfully requested to remove the petition from the docket. The order addressed access and redactions; the opinion text does not state a ruling on the merits of the petition to vacate the arbitration award.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.