Hanks v. Voya Retirement Insurance and Annuity Company of New York
- P. Castel
- 1:16-cv-06399
- U.S. District Court · Southern District of New York
- 8
In Hanks v. Voya, Judge Castel granted in part and denied in part a motion to seal summary-judgment documents.
Voya Retirement Insurance and Annuity Company, non-party The Lincoln Life & Annuity Company of New York, Helen Hanks, and members of the public seeking access to the summary-judgment filings.
What happened
Hanks v. Voya Retirement Insurance and Annuity Company concerned a request by Voya and non-party Lincoln Life to seal or redact documents filed with the parties’ summary-judgment motions. Helen Hanks opposed the request.
The court granted the request for redactions in 14 exhibits because they protected sensitive business information, including actuarial assumptions, insurance rates, financial metrics, regulatory communications, and settlement details. It denied the request for redactions in 12 other exhibits because the information was general and the movants did not show that disclosure would cause enough commercial harm to overcome public access. Seventeen exhibits no longer required sealing.
Judge P. Kevin Castel ordered the parties to publicly file unredacted versions of the documents covered by the denied requests within 14 days and directed the Clerk to terminate the motion.
The detailed version
- Hanks v. Voya Retirement Insurance and Annuity Company of New York · No. 1:16-cv-06399
- P. Castel
- Sept. 30, 2020
Background
Voya Retirement Insurance and Annuity Company and non-party The Lincoln Life & Annuity Company of New York moved to seal or redact documents submitted with Voya’s and Helen Hanks’s motions for summary judgment. Hanks opposed the motion. The documents had previously been filed with redactions or under temporary seal.
Legal standard
The court applied the common-law and First Amendment rights of public access to judicial documents. Documents filed in connection with summary judgment receive a strong presumption of public access because they may influence the court’s decision. Sealing or redaction is allowed when a countervailing interest, such as protection of confidential business information, outweighs public access. Any restriction must be narrowly tailored, and redaction is generally preferred to sealing an entire document.
Ruling
The court found that all documents covered by the motion were judicial documents and therefore subject to at least some presumption of public access. It individually reviewed the documents and determined that the stronger presumption applicable to summary-judgment materials required document-specific findings.
The court granted Voya’s motion to seal as to proposed redactions in Exhibits 1, 4, 5, 12, 13, 14, 15, 21, 26, 30, 31, 33, 41, and 42. These redactions covered sensitive business information, including specific actuarial assumptions, cost-of-insurance rates, financial metrics, confidential communications with state insurance regulators, and details of negotiated settlements. The court found that disclosure could cause commercial harm and that the redactions were narrowly tailored.
The court denied Voya’s motion to seal as to proposed redactions in Exhibits 6, 8, 9, 10, 11, 19, 20, 25, 27, 28, 32, and 36. These materials concerned Voya’s review process and included general information, vague deposition responses, and lists of factors. The court found that the movants had not shown that this information was specific or sensitive enough to give competitors an advantage or cause commercial harm. The parties were ordered to file unredacted versions of these documents within 14 days.
The movants no longer sought confidential treatment for Exhibits 2, 3, 7, 16, 17, 18, 22, 23, 24, 29, 34, 35, 37, 38, 39, 40, and 43. The court stated that no further action was required for those exhibits because unredacted versions were publicly available on the docket.
Disposition
Judge P. Kevin Castel ordered the Clerk to terminate the motion. The court also directed public filing of unredacted versions of the documents covered by the denied requests within 14 days.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.