Anderson v. New York City Health and Hospitals Corporation
- Katharine Parker
- 1:16-cv-01051
- U.S. District Court · Southern District of New York
- 6
In Anderson v. New York City Health and Hospitals Corporation, Judge Parker granted in part and denied in part requests to seal resumes, requiring redaction of private contact information.
The ruling affected the parties’ requests to seal the resumes of Jessica Erickson, Horowitz, Edith Burton-Jones, and Yesenia Cosme, as well as public access to those documents. It required redaction of their home addresses, phone numbers, and email addresses but denied broader sealing.
What happened
In Anderson v. New York City Health and Hospitals Corporation, the parties asked the court to seal resumes submitted with a motion for summary judgment in an employment-discrimination case. The resumes belonged to Jessica Erickson, Horowitz, Edith Burton-Jones, and Yesenia Cosme, whose names and promotion information had already been publicly disclosed.
The court found that the resumes were judicial documents subject to a strong presumption of public access because they helped the public understand the court’s analysis. It also found that home addresses, phone numbers, and email addresses were private and not relevant to that analysis.
Judge Katharine H. Parker granted in part and denied in part the requests to seal. She ordered the parties to redact those private contact details and file the redacted resumes by March 18, 2020, while denying sealing of the remaining information.
The detailed version
- Anderson v. New York City Health and Hospitals Corporation · No. 1:16-cv-01051
- Katharine Parker
- Mar. 4, 2020
Background
Alexander Anderson sued New York City Health and Hospitals Corporation and other defendants under Title VII of the Civil Rights Act of 1964 and the New York City Human Rights Law. He alleged discrimination, retaliation, and denial of promotions by his former employer. The defendants moved for summary judgment, and the parties submitted Anderson’s resume and the resumes of Jessica Erickson, Horowitz, Edith Burton-Jones, and Yesenia Cosme to compare qualifications for the promotions.
The parties filed letter motions asking to place those four third parties’ resumes under seal. The opinion identifies the motions as docket entries 167 and 179. The parties had already identified the four individuals and their promoted positions in publicly filed documents.
Legal standard
The court explained that judicial documents—documents submitted in connection with a dispositive motion such as summary judgment—carry a strong presumption of public access. A party seeking to overcome that presumption must show that sealing is necessary to protect a higher value and is narrowly tailored. Privacy interests of innocent third parties may qualify as such a value, particularly for personal information such as names, addresses, and contact details.
Court’s analysis
The court found that the resumes were judicial documents because they were submitted in support of or opposition to the summary-judgment motion. The court also stated that its report and recommendation on that motion relied heavily on the resumes and described them in detail. Public access to the resumes’ relevant information would therefore help people understand the issues and evaluate the court’s reasoning.
The court distinguished between information already made public and information that remained private. Names, qualifications, and promoted positions had already been disclosed. Home addresses, personal phone numbers, and email addresses had not been publicly disclosed, were not relevant to the report and recommendation, and were the type of personal information courts had recognized as deserving protection.
Disposition
The court granted in part and denied in part the motions to seal. It ordered the parties to redact the home addresses, phone numbers, and email addresses of Erickson, Horowitz, Burton-Jones, and Cosme from the resumes and job applications, and to file the redacted exhibits on the docket by March 18, 2020. The court denied sealing of the remaining information.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.