Kumaran v. National Futures Association

Background

The court considered Defendant Kadlec’s letter motion to seal certain portions of a Guaranty & Fee Agreement filed as an exhibit to the amended complaint. A plaintiff objected to the request.

Legal standard

The court applied the Second Circuit’s three-part test for sealing court records. It first considered whether the material was a judicial document, meaning a document relevant to the court’s exercise of judicial power. It then considered the strength of the public’s common-law right to access the material and balanced that interest against competing considerations.

Analysis

Because the agreement was attached to the amended complaint, the court found that it was a judicial document. However, the court found that the presumption of public access to the proposed redactions was comparatively low because the amended complaint did not refer to or quote the information that Defendant Kadlec sought to keep confidential. The court also found that the redactions were narrowly tailored to protect competitive business information. It concluded that this interest justified sealing the redacted material.

Disposition

Judge Stewart D. Aaron granted the letter motion to seal.

Note on the record

The supplied case metadata identifies Gregory Woods as the judge, but the opinion is signed by Stewart D. Aaron, United States Magistrate Judge. This summary uses the judge named in and signing the opinion.