Haley v. Teachers Investment and Annuity Association
- James Oetken
- 1:17-cv-00855
- U.S. District Court · Southern District of New York
- 3
In Haley v. Teachers Insurance, Judge Lehrburger SO-ORDERED limited sealing of TIAA’s confidential cost figures.
TIAA, whose specified internal cost figures were allowed to remain redacted and sealed, and the public, which was denied access to those limited portions of the filings. The rest of the identified motion papers and opposition remained public.
What happened
In Haley v. Teachers Insurance and Annuity Association of America, TIAA asked to redact and seal specific dollar amounts showing its costs for providing participant loan services. Plaintiff did not consent to sealing those portions.
TIAA argued that disclosure could reveal confidential business operations and cause competitive harm. It asked to seal only limited portions of three pages, while leaving the other filings publicly available and unredacted.
Judge Robert W. Lehrburger entered the order marked “SO ORDERED,” allowing the requested limited protection for the specified cost figures. The order did not seal the broader motion papers or opposition.
The detailed version
- Haley v. Teachers Investment and Annuity Association · No. 1:17-cv-00855
- James Oetken
- June 10, 2020
Background
TIAA submitted a letter asking the court to permit limited redactions and sealing of specific dollar amounts in three filings connected to Plaintiff’s motion to compel discovery. The amounts appeared in Exhibits C and D to a declaration supporting Plaintiff’s motion and in several lines of a deposition transcript attached to TIAA’s opposition.
TIAA said the figures represented its actual costs incurred or allocated for providing participant loan services. It asserted that the information was designated confidential under the case’s protective order and that public disclosure could give competitors insight into TIAA’s business operations and cause competitive harm.
TIAA stated that it had agreed to remove nearly all other redactions in the filings, including all redactions in the motion to compel, the supporting declaration, and several exhibits. It sought continued redaction only for the specified dollar figures. Plaintiff did not consent to sealing those portions.
TIAA had previously made a narrower sealing request, which the court denied without prejudice because the request did not describe the information and deposition portions with enough specificity. The renewed request identified the documents, pages, rows, columns, and transcript lines involved.
Court’s action
The letter ends with the notation “SO ORDERED” and the signature of United States Magistrate Judge Robert W. Lehrburger. The order therefore allowed the limited redactions and sealing requested for the specified business-cost figures. The request was narrowly limited to ancillary supporting material; TIAA did not seek to seal Plaintiff’s motion to compel or TIAA’s opposition.
The opinion relied on the principle that judicial documents generally carry a presumption of public access, but that presumption may be overcome by higher values such as protection from competitive injury. It treated the limited internal cost figures as confidential business information and distinguished a case involving alleged wrongdoing by a public entity.
Result and effect
The ruling protects the identified dollar amounts from public disclosure while leaving the rest of the relevant filings public. It concerns document access in the discovery dispute and does not decide the underlying motion to compel or the merits of the case.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.