Olson v. Major League Baseball

Background

The plaintiffs are players in DraftKings fantasy baseball contests who brought a putative class action against Major League Baseball, MLB Advanced Media, L.P., the Houston Astros, LLC, and the Boston Red Sox Baseball Club, L.P. Their amended complaint asserted fraud, negligence, unjust enrichment, and consumer-protection claims. The court had previously dismissed the action with prejudice and later denied the plaintiffs’ request for reconsideration and permission to file an amended complaint.

During the reconsideration proceedings, the plaintiffs submitted a letter from MLB Commissioner Robert Manfred to the general manager of the New York Yankees. The letter discussed an MLB investigation into possible misconduct by the Yankees and had been obtained during discovery. MLB and the Yankees asked that it remain under seal. The plaintiffs opposed continued sealing.

Legal framework

The court explained that judicial documents carry a common-law presumption of public access. It applied a three-step test: whether the document is a judicial document, how strong the presumption of access is, and whether competing interests outweigh that presumption.

Analysis

The court found that the letter was a judicial document because it was relevant to the court’s resolution of the reconsideration motion and was discussed in the court’s earlier order. The court also found that the presumption of access was especially strong. The letter was submitted in connection with a motion addressing the dismissal of the case, formed a primary basis for the plaintiffs’ reconsideration arguments, and was important to understanding the court’s reasoning.

MLB and the Yankees argued that their privacy interests outweighed public access. The court rejected that argument. It reasoned that much of the letter’s substance had already been made public through a 2017 press release and that the defendants had not identified a sufficiently significant injury from disclosure. The court also found that the privacy interests of individuals mentioned in the letter could be protected by redacting their names. The court found no evidentiary basis to consider the defendants’ allegations that the plaintiffs were acting in bad faith.

Disposition

The court found that the Yankees Letter should be unsealed. It gave MLB and the Yankees an opportunity to submit a minimally redacted version by noon on June 15, 2020. At the Yankees’ request, the court stayed unsealing until June 19, 2020, to allow the Yankees to seek emergency appellate review in the Second Circuit under 28 U.S.C. § 1291.