Doe v. Sarah Lawrence College
- Philip Halpern
- 7:19-cv-10028
- U.S. District Court · Southern District of New York
- 1
In Jane Doe v. Sarah Lawrence College, Judge Halpern granted defendants’ request to file anticipated motion exhibits under seal.
The defendants, the pseudonymously named plaintiff Jane Doe, and nonparty Sarah Lawrence College students whose identifying information appeared in the anticipated motion exhibits.
What happened
In Jane Doe v. Sarah Lawrence College, the defendants asked to file exhibits supporting an anticipated motion to dismiss under seal. They said the exhibits contained sensitive identifying information about the plaintiff and other Sarah Lawrence College students involved in disciplinary proceedings.
The defendants argued that redacting the information would make the documents difficult to read and use. The plaintiff’s lawyer agreed to the request. The court granted the application.
Judge Halpern ruled that, although the exhibits were court records subject to a presumption of public access, the defendants had shown enough to justify filing them under seal. This order did not decide the anticipated motion to dismiss or the underlying claims.
The detailed version
- Doe v. Sarah Lawrence College · No. 7:19-cv-10028
- Philip Halpern
- Dec. 16, 2019
Background
The defendants notified the court that they intended to file a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). They asked for permission to file the motion’s exhibits under seal. According to the defendants, the exhibits contained highly sensitive information, including the names of the plaintiff and other Sarah Lawrence College students involved in disciplinary proceedings, as well as telephone numbers, email addresses, and dormitory information.
The plaintiff had already been permitted to proceed using a pseudonym. The defendants argued that the same concerns supported sealing the exhibits, particularly because some identifying information concerned students who were not parties to the case. They also said that redacting the information would make the documents cumbersome for the parties and the court to read and use. The plaintiff’s counsel consented to the request.
Ruling
The court granted the application. It recognized that the exhibits were judicial documents subject to a common-law and First Amendment presumption of public access. The court nevertheless found that the defendants had shown a sufficient basis to justify filing the exhibits under seal. The order addressed only the sealing request; it did not rule on the anticipated motion to dismiss or the merits of the lawsuit.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.