Johnson v. L'Oreal USA
- John Cronan
- 1:18-cv-09786
- U.S. District Court · Southern District of New York
- 2
In Amanda Johnson v. L’Oreal USA, Judge Cronan provisionally sealed two exhibits because non-parties’ privacy interests outweighed public access.
The order affects the non-parties whose sensitive personal information appears in the exhibits, the parties seeking to use those exhibits, and members of the public seeking access to the court records.
What happened
In Amanda Johnson v. L’OREAL USA, the Court considered whether Exhibits 3 and 30 should remain redacted and sealed while Defendant’s summary-judgment motion was pending.
The Court said the parties’ agreement alone was not enough to justify sealing. But it found that the privacy interests of non-parties outweighed the public’s right to access the exhibits, and that the proposed redactions were narrowly limited.
Judge John P. Cronan provisionally sealed the exhibits and said the Court would reconsider continued sealing when deciding the summary-judgment motion. The Clerk was directed to terminate the motion at Docket Number 122.
The detailed version
- Johnson v. L'Oreal USA · No. 1:18-cv-09786
- John Cronan
- Apr. 14, 2021
Background
The Court considered Plaintiff’s request, made on behalf of Defendant, to seal Exhibits 3 and 30 to Docket Number 112. The parties submitted redacted versions of those exhibits and jointly agreed that the exhibits should remain redacted while Defendant’s motion for summary judgment was pending.
The Court noted that the parties’ consent by itself did not justify sealing court documents. Defendant asserted that the documents were significantly prejudicial and contained sensitive, personal, and potentially embarrassing private information about individuals involved in the action. The Court also noted that the parties had not apparently submitted highlighted versions showing the proposed redactions as required by the Court’s individual rules, although the Court compared the sealed exhibits with the proposed redacted versions.
Ruling
The Court concluded that the privacy interests of non-parties outweighed the presumption that court documents should be publicly accessible. It also concluded that the proposed redactions were narrowly tailored and essential to protect those interests. The Court therefore provisionally sealed Exhibits 3 and 30 and stated that it would reassess whether they should remain sealed when considering Defendant’s motion for summary judgment. The Clerk was directed to terminate the motion at Docket Number 122. The order did not decide Defendant’s motion for summary judgment.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.