JLM Couture, Inc. v. Gutman
- Laura Swain
- 1:20-cv-10575
- U.S. District Court · Southern District of New York
- 3
In JLM Couture v. Gutman, Judge Swain approved redactions and kept supporting exhibits sealed to protect private information.
JLM Couture, Inc., Hayley Paige Gutman, the public’s access to the exhibits, and third parties and their employees whose private information appeared in the materials.
What happened
JLM Couture, Inc. v. Gutman concerned Defendant Hayley Paige Gutman’s request to redact information from third-party exhibits filed by Plaintiff JLM Couture, Inc. The information included third parties’ employees’ names and contact information, digital-workspace access information, contract terms, and the contact information and contract terms of Gutman’s fiancé.
The court treated the exhibits as judicial documents because it had relied on portions of them when granting JLM Couture’s preliminary-injunction motion. But it had not relied on the information proposed for redaction. The court therefore gave the public-access presumption minimal weight and found that disclosure could cause competitive injury and harm third parties’ privacy interests.
Judge Swain granted Gutman’s redaction request in its entirety. The court approved the redactions in docket entry 111 and ordered docket entry 113 to remain sealed, with access limited to the parties and the court.
The detailed version
- JLM Couture, Inc. v. Gutman · No. 1:20-cv-10575
- Laura Swain
- Aug. 2, 2021
Background
Defendant Hayley Paige Gutman filed a letter motion asking the court to approve Plaintiff JLM Couture, Inc.’s proposed redactions to certain third-party exhibits filed at docket entry 111. The proposed redactions covered information about third parties who were not parties to the case, including their employees’ identification and contact information, access information for non-public digital workspaces, provisions of Gutman’s contracts with those third parties, Gutman’s fiancé’s contact information, and provisions of her fiancé’s contract with one of the third parties. Gutman’s motion and supporting exhibits were filed under seal at docket entry 113.
Court’s Analysis
The court explained that the public generally has a right to inspect and copy judicial records. It also recognized a stronger right of public access under the First Amendment, the constitutional protection for freedom of speech and press. Because the court had relied on portions of the exhibits in granting JLM Couture’s motion for a preliminary injunction, the exhibits were judicial documents subject to a presumption of public access.
The court found, however, that it had not relied on any of the information proposed for redaction. It therefore gave the public-access presumption minimal weight. The court concluded that the presumption was outweighed by the competitive injury that could result from publicly disclosing contract provisions and non-public workspace access information, as well as the privacy harms to third parties and their employees from disclosing identification and contact information. The court also found that the proposed redactions were necessary to protect those interests and were narrowly limited to them.
Disposition
Judge Laura Taylor Swain granted Gutman’s redaction request in its entirety. The court approved the redactions in docket entry 111 and ordered docket entry 113 to remain under seal, with access restricted to the parties and the court. The order resolved docket entry 112.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.