Williams v. NYU Hospital Center Finance & Payroll Support
- Louis Stanton
- 1:19-cv-11612
- U.S. District Court · Southern District of New York
- 2
In Williams v. NYU Hospital Center Finance & Payroll Support, Judge McMahon restricted access to a filing containing private information and denied fee-free appeal status.
Sean L. Williams, his two minor children whose personal information appeared in the filing, and people seeking electronic access to the complaint.
What happened
In Williams v. NYU Hospital Center Finance & Payroll Support, Sean L. Williams, representing himself and without paying filing fees, alleged that the defendant unlawfully garnished his wages. An attachment included his full Social Security number, his minor children’s full names, and birthdates.
The court ordered the Clerk to limit electronic access to the complaint to case participants because it revealed the children’s full names and birthdates. The court also directed Williams to follow the federal filing rule requiring redaction of such information in future documents.
Chief Judge Colleen McMahon ordered that a copy be mailed to Williams and stated that an appeal would not be taken in good faith, so Williams was denied fee-free status for an appeal. The order did not decide whether the wage garnishment was lawful.
The detailed version
- Williams v. NYU Hospital Center Finance & Payroll Support · No. 1:19-cv-11612
- Louis Stanton
- Jan. 10, 2020
Background
Sean L. Williams filed a complaint alleging that NYU Hospital Center Finance & Payroll Support unlawfully garnished his wages. The opinion states that Williams represented himself and was proceeding without paying filing fees. The complaint included an attachment containing Williams’s full Social Security number, the full names of his two minor children, and Williams’s and his children’s full birthdates.
Privacy ruling
Federal Rule of Civil Procedure 5.2(a) generally requires court filings to include only the last four digits of a Social Security number, only the year of a person’s birth, and only a minor child’s initials. Because the attachment revealed the minor children’s full names and birthdates, the court directed the Clerk of Court to restrict electronic access to the complaint, identified as ECF No. 2, to people participating in the case. The court also directed Williams to comply with Rule 5.2(a)(3) in future filings.
Appeal-fee ruling and disposition
The court directed the Clerk to mail Williams a copy of the order and record service on the docket. Under 28 U.S.C. § 1915(a)(3), the court certified that an appeal from the order would not be taken in good faith and denied Williams fee-free status for an appeal. The order did not address the merits of Williams’s wage-garnishment allegation. Chief Judge Colleen McMahon entered the order on January 10, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.