Leonard v. John Hancock Life Insurance Company of New York

Background

The plaintiffs filed a redacted First Amended Class Action Complaint. The defendants, John Hancock Life Insurance Company of New York and John Hancock Life Insurance Company (U.S.A.), asked the court to maintain portions of Paragraphs 15, 54, and 61 under seal. The plaintiffs also filed a motion to seal, identified as ECF No. 115.

Reasoning

The court explained that pleadings generally are accessible to the public, but portions may be sealed when necessary to protect an important legally protected interest and when the proposed redactions are narrowly limited. The court determined that the challenged passages quoted or paraphrased information protected by Canada’s Insurance Companies Act and related regulations. That protected category included supervisory reports and related correspondence prepared for or submitted to Canada’s Office of the Superintendent of Financial Institutions. The court stated that some of this information came from reports prepared by John Hancock’s parent company, Manulife Financial Corporation, for that Canadian regulator.

The court found the proposed redactions narrowly tailored because they covered only a handful of phrases in the 163-paragraph complaint and were no broader than necessary to protect the legally protected information.

Ruling

The court granted the defendants’ motion to maintain under seal portions of Paragraphs 15, 54, and 61, as shown in Exhibit A to the defendants’ motion. It ordered that the redactions be limited to those in Exhibit A. The court denied the plaintiffs’ motion to seal in all other respects and directed the Clerk to terminate the open motions identified as ECF Nos. 115 and 121.