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S.D.N.Y.Procedural orderFiled Dec. 14, 2020

Watson v. Manhattan Luxury Automobiles, Inc. d/b/a Lexus Of Manhattan

Judge
Lorna Schofield
Docket
1:20-cv-04572
Court
U.S. District Court · Southern District of New York
Pages
2
Civil Procedure
In one sentence

In Watson v. Manhattan Luxury Automobiles, Judge Schofield granted a request to refile exhibits with Honda customers’ personal information redacted.

Who this affects

Manhattan Luxury Automobiles, Inc. d/b/a Lexus of Manhattan must refile the specified letter and exhibits with Honda customer personal information redacted; the Honda customers’ privacy interests are protected from public disclosure.

What happened

In Watson v. Manhattan Luxury Automobiles, the defendant asked to seal or redact three exhibits containing text messages and charts with Honda customers’ telephone numbers and other customer information.

The court found that the proposed redactions were narrowly tailored and necessary to protect personal identifying information. The redactions would not prevent the public from understanding the case’s merits.

Judge Lorna G. Schofield granted the application and ordered the defendant to refile the December 9, 2020 letter and its exhibits by December 16, 2020, with Honda customer personal information redacted.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Watson v. Manhattan Luxury Automobiles, Inc. d/b/a Lexus Of Manhattan · No. 1:20-cv-04572
Judge
Lorna Schofield
Date
Dec. 14, 2020

Background

Manhattan Luxury Automobiles, Inc. d/b/a Lexus of Manhattan asked to seal, or alternatively refile in redacted form, three exhibits attached to its December 9, 2020 letter. The exhibits included sample text messages sent by Manhattan Lexus to Honda customers and sample charts containing those customers’ telephone numbers and other customer information. The opinion text does not describe the underlying claims in the case.

Court’s analysis

The court recognized that the public has a firmly established common-law right to access judicial documents, but explained that the right is not absolute. Courts must balance public access against competing interests. Here, the proposed redactions were narrowly tailored and necessary to prevent the disclosure of personal identifying information. The court also found that the redactions would not impair the public’s ability to understand the merits of the case.

Ruling

Judge Lorna G. Schofield granted the application. The defendant was ordered to refile the December 9, 2020 letter at Docket No. 56 and its exhibits by December 16, 2020, with Honda customer personal information redacted.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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