Lodging Solutions, LLC v. Miller
- Alison Nathan
- 1:19-cv-10806
- U.S. District Court · Southern District of New York
- 2
In Lodging Solutions v. Miller, Judge Nathan granted the plaintiff’s request to redact limited sensitive information from two preliminary-injunction hearing transcripts.
The ruling affects the plaintiff’s ability to redact the two hearing transcripts and protects the identified client and employee names and API business information from public disclosure.
What happened
Lodging Solutions, LLC v. Miller concerns the plaintiff’s request to redact portions of transcripts from a December 2019 preliminary-injunction hearing. The requested redactions covered client names, names of employees unrelated to the case, and sensitive business information regarding API.
The court said public access to court records must be balanced against privacy and business interests. It found that the information was not material to the court’s decision and that the proposed redactions were limited to sensitive information and identifying details of third parties unconnected to the case.
Judge Alison J. Nathan granted the request to redact portions of the December 17 and December 19 hearing transcripts. The available text also directs the plaintiff to file the redacted transcripts, but it cuts off before providing any further filing details.
The detailed version
- Lodging Solutions, LLC v. Miller · No. 1:19-cv-10806
- Alison Nathan
- Nov. 23, 2020
Background
The plaintiff asked for permission to redact portions of transcripts from the December 17 and December 19, 2019 preliminary-injunction hearing. The proposed redactions covered three categories: API’s client names; names of employees of API’s clients who were not relevant to the case; and sensitive business information regarding API.
Legal standard
The court applied the public-access standard for judicial documents. A judicial document is one relevant to the court’s work or useful in the judicial process, or one that tends to influence the court’s ruling. Such documents generally carry a presumption of public access. The court must balance that presumption against interests such as privacy, protection of sensitive business information, and efficient judicial administration. Information that does not directly affect the court’s decision may receive less protection from the public-access presumption.
Analysis
The court stated that the proposed redactions were minimal and warranted. It found that the information was not material to its adjudication and included sensitive business information. It also found that the redactions were narrowly tailored because they were limited to sensitive business information and identifying information concerning third parties with no connection to the case.
Disposition
For the reasons stated in the court’s January 15, 2020 order, the request to redact portions of the December 17 and December 19 hearing transcripts was granted. The order also states that the plaintiff shall file the redacted transcripts, but the available text ends before giving additional filing instructions.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.