Ramirez v. Group Short Term Disability
Ramirez v. Group Short Term Disability, Long Term Disability and Life Plan for Employees of ZB Company, Inc.
- Lorna Schofield
- 1:20-cv-09624
- U.S. District Court · Southern District of New York
- 2
In Ramirez v. Hartford Life, Judge Schofield ordered the parties to file a redacted administrative record after reviewing a request to seal it.
The parties and the public’s access to the administrative record were affected. The parties were required to submit a version with proposed redactions rather than seek to seal the entire record.
What happened
In Glenna D. Ramirez v. Hartford Life and Accident Insurance Company, the parties jointly asked to seal the administrative record because it contained personal information and protected health information.
The court noted that the record also contained general information about the benefits plans and correspondence about Ramirez’s benefits claims, which did not warrant sealing. The court also noted that the parties had not filed the record under seal when they submitted their motion.
Judge Lorna G. Schofield ordered the parties to file the administrative record with proposed redactions by March 26, 2021.
The detailed version
- Ramirez v. Group Short Term Disability · No. 1:20-cv-09624
- Lorna Schofield
- Mar. 12, 2021
Background
The parties jointly moved to seal the administrative record, citing the record’s extensive references to Plaintiff’s personal information and protected health information. The court stated that the motion did not include a copy of the administrative record temporarily filed under seal, as required by the court’s Individual Rule I.D.3. On March 11, 2021, the court directed the parties to file a copy of the record under seal.
Legal Standard
The court explained that judicial documents are generally subject to a common-law right of public access. Courts must balance that presumption against competing considerations, including the facts and circumstances of the particular case.
Ruling
The court found that sealing was appropriate for the record’s many references to Plaintiff’s personal information and protected health information. It also found that sealing was not appropriate for general information about the benefits plans at issue or correspondence concerning Plaintiff’s benefits claims. The court ordered the parties to file the administrative record with proposed redactions by March 26, 2021.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.