Ramirez v. Group Short Term Disability

Background

The parties jointly moved to seal the administrative record. They stated that the record contained extensive references to Plaintiff Glenna D. Ramirez’s personal information and protected health information, meaning health information that is legally protected from unauthorized disclosure.

The initial motion did not include a copy of the administrative record filed temporarily under seal, as required by the court’s individual rules. The court later directed the parties to file the record under seal, which they did. The court then required proposed redactions because the record also contained general information about the benefits plans and correspondence concerning Ramirez’s benefits claims.

Court’s Analysis

The court recognized the public’s common-law right to access judicial documents. It explained that a court deciding whether to seal filings must balance that presumption of public access against competing interests, including the need to prevent unauthorized disclosure of personal information and protected health information.

The court determined that sealing was appropriate for the personal information and protected health information in the administrative record, but that the general plan information and benefits correspondence did not warrant sealing. The parties therefore filed a redacted version as directed.

Ruling

Judge Lorna G. Schofield granted the parties’ motion to seal the unredacted version of the administrative record. The administrative record at Docket No. 22 must remain under seal, and access is limited to the individuals identified in the appendix. The appendix identifies attorneys of record Christopher Foley and Matthew Mazzola as having access to the sealed documents.