Jin v. Choi
- Stewart Aaron
- 1:20-cv-09129
- U.S. District Court · Southern District of New York
- 3
In Jin v. Choi, Magistrate Judge Aaron granted in part and denied in part Jin’s request to seal court documents.
Yutong Jin’s medical records at ECF No. 31-2 will be placed under seal. The request was denied as to the other documents, including materials involving Solomon Choi and settlement discussions.
What happened
In Jin v. Choi, Yutong Jin asked the court to seal five previously filed documents, including messages, medical records, a legal memorandum, a hearing transcript, and a letter discussing settlement negotiations.
The court found that most of the documents had already been publicly available for months, weakening any privacy interest in sealing them. It also found that similar health information was already publicly described. The court nevertheless concluded that Jin’s medical records contained detailed treatment information and should be sealed.
The court granted in part and denied in part Jin’s request: it granted the request as to the medical records at ECF No. 31-2 and denied it as to the remaining documents. Magistrate Judge Stewart D. Aaron directed the Clerk of Court to place the medical records under seal.
The detailed version
- Jin v. Choi · No. 1:20-cv-09129
- Stewart Aaron
- June 17, 2021
Background
Yutong Jin asked the court to seal five documents that had already been filed publicly: (1) messages between Jin and Solomon Choi, filed as Exhibit 1 to Jin’s reply; (2) Jin’s medical records, filed as Exhibit 2 to the reply; (3) Jin’s memorandum of law; (4) the transcript of a January 12, 2021 telephone conference; and (5) a letter referring to settlement discussions.
Court’s analysis
The court applied the standards for sealing judicial documents described in Lugosch v. Pyramid Co. of Onondaga. It explained that the documents had been available on the public docket for at least one month, and some for four or five months. That public availability weakened the asserted privacy interests because the court could not make private information that had already become public.
The court also noted that the messages’ reference to Jin’s medical condition was similar to information already described in the publicly available complaint. The memorandum’s references to Choi’s mental health and health information discussed during the telephone conference likewise concerned information the court found had already been publicly disclosed.
The court treated the medical records differently. Although Jin had filed them publicly almost four months earlier, the records contained detailed treatment notes. The court found that Jin retained significant privacy rights in her medical information and concluded that sealing the records was justified.
As to the settlement letter, the court stated that there is no presumptive right of public access to settlement discussions and related documents. But Jin had filed the letter and attached emails publicly and had already redacted some information, including the settlement amount. The court found that Jin had not met her burden to show that the entire letter should be sealed.
Disposition
The court granted in part and denied in part Jin’s request to file documents under seal. It granted the request as to the medical records at ECF No. 31-2 and denied it as to the remaining documents. The Clerk of Court was requested to place ECF No. 31-2 under seal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.