Rinaldi v. SCA La Goutte, D'Or
- Vernon Broderick
- 1:16-cv-01901
- U.S. District Court · Southern District of New York
- 3
In Rinaldi v. SCA La Goutte, Judge Broderick granted a request to redact a witness’s confidential personal information from a hearing transcript.
SCA La Goutte, SAS Ch. & A. Prieur, the witness whose personal information appears in the transcript, and members of the public seeking access to the transcript were affected. The court allowed only a redacted version to be publicly available.
What happened
In Rinaldi v. SCA La Goutte, SCA La Goutte and SAS Ch. & A. Prieur asked the court to redact personal information from a transcript of a January 21, 2022 conference about testimony from France. The plaintiff did not object to filing the request under seal.
The request concerned information that was not publicly known and had already been redacted and sealed in related filings. The requesters argued that protecting the witness’s privacy and personal data outweighed the limited public interest in seeing those portions of the transcript.
Judge Vernon S. Broderick granted the application and ordered the requested redactions, with only the redacted transcript to be publicly available. The opinion states that the redactions were narrowly tailored to protect confidential personal information and data covered by the European Union’s General Data Protection Regulation.
The detailed version
- Rinaldi v. SCA La Goutte, D'Or · No. 1:16-cv-01901
- Vernon Broderick
- Mar. 14, 2022
Background
SCA La Goutte and SAS Ch. & A. Prieur, identified as defendants and counterclaim plaintiffs, asked the court to redact portions of the transcript of a January 21, 2022 conference. The conference concerned remote trial testimony by a witness from France. The requested redactions involved personal information about the witness. The plaintiff’s counsel stated that the plaintiff did not object to the request being filed in redacted form and under seal.
The requesters noted that the court had previously allowed related documents containing the same personal information to remain redacted and sealed. They asked that the transcript be redacted in the same way and that only the redacted version be placed on the public docket.
Court’s reasoning
The letter explained that judicial documents generally carry a common-law presumption of public access, but that presumption can be overcome by a sufficiently compelling countervailing interest. Privacy interests may outweigh public access when the request is supported by a particularized showing and the redactions are narrowly tailored.
The court accepted the stated basis for protecting the information. The information was not publicly known, did not concern public health or safety, did not involve a public entity or official, and was not central to the parties’ underlying claims. The court also considered the privacy interest in preventing disclosure of a witness’s personal information and the earlier sealing of documents containing the same information. The requested redactions were limited to the portions addressing that information and were intended to protect personal data covered by the European Union’s General Data Protection Regulation.
Ruling
The court’s order states “APPLICATION GRANTED” and “SO ORDERED.” The court therefore granted the request to redact the specified portions of the transcript and directed that only the redacted transcript be publicly available. The ruling addressed access to and redaction of a hearing transcript, not the merits of the underlying claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.