Robinson v. De Niro
- Lewis Liman
- 1:19-cv-09156
- U.S. District Court · Southern District of New York
- 2
Robinson v. De Niro: Judge Liman granted the defendants’ request to seal a psychiatric-evaluation exhibit to protect Robinson’s privacy.
Graham Chase Robinson’s private psychiatric information was protected from public disclosure in the specified exhibit; the defendants were permitted to file that exhibit under seal, and public access to it was restricted.
What happened
In Graham Chase Robinson v. Canal Productions, Inc. et al., the defendants asked to file under seal an exhibit containing Robinson’s psychiatric evaluation by her expert. The exhibit was to support a forthcoming request for a court-ordered medical examination.
The request argued that confidential medical information deserves protection and that Robinson’s privacy interest outweighed the public’s interest in access to the filing. The court’s notation states that the application was granted.
Judge Lewis Liman granted the request to seal the exhibit. The materials do not state that the entire case was sealed or that any other relief was granted.
The detailed version
- Robinson v. De Niro · No. 1:19-cv-09156
- Lewis Liman
- Apr. 1, 2022
Background
Defendant Canal Productions, Inc., represented with defendant Robert De Niro, submitted a letter asking for permission to file an exhibit under seal. The exhibit was a psychiatric evaluation of plaintiff Graham Chase Robinson conducted by her expert, Robert Lloyd Goldstein, M.D. The exhibit was to be attached to materials supporting the defendants’ forthcoming motion under Federal Rule of Civil Procedure 35.
Reasoning
The request relied on the court’s authority to restrict public access to court records when necessary to prevent improper use, as well as Federal Rules of Civil Procedure 5.2(d) and 26(c)(1). Those rules allow protection from annoyance, embarrassment, oppression, or undue burden when there is good cause. The filing also cited decisions recognizing that confidential medical information can outweigh the presumption that court records are public. It argued, and the court’s notation reflects, that Robinson’s privacy interest in her psychiatric evaluation outweighed the interest in public disclosure.
Ruling
The application to file the exhibit under seal was granted. The provided materials do not state that the entire action was sealed, that the parties were allowed to proceed anonymously, or that any other motion was decided. The letter is addressed to Magistrate Judge Katharine H. Parker and bears an “APPLICATION GRANTED” notation, while the supplied case metadata identifies Lewis Liman as the judge; the materials therefore contain an unresolved discrepancy about the judicial officer associated with this ruling.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.