Abraham v. Leigh
- Katherine Failla
- 1:17-cv-05429
- U.S. District Court · Southern District of New York
- 2
In Abraham v. Leigh, Judge Failla denied Abraham’s request to seal docket entry 692 because the record did not support her claimed risks.
Robyn Abraham’s request to seal docket entry 692 was denied, leaving the citation-related information subject to the court’s public docket.
What happened
In Abraham v. Leigh, Robyn Abraham asked the court to seal docket entry 692, which contained citations to two California cases mentioned in her earlier sanctions motion. She said publicly listing information about those cases could expose her to retaliation and physical harm.
The court denied the request. It found no evidence supporting those claimed risks and noted that Abraham had herself filed related information publicly. The court also saw no reason to seal citation information about public court proceedings.
Judge Katherine Polk Failla issued the order on May 20, 2022. The ruling left docket entry 692 unsealed.
The detailed version
- Abraham v. Leigh · No. 1:17-cv-05429
- Katherine Failla
- May 20, 2022
Background
Robyn Abraham asked the court to seal docket entry 692. The document included citations to two California cases that Abraham had referenced in an earlier motion seeking sanctions. Abraham argued that the court’s public listing of information about those cases could subject her to further retaliation and potential physical harm.
Court’s reasoning
The court found no indication that merely referencing the California cases would affect the resolution of the case. It also found no evidence in the record supporting Abraham’s allegations of retaliation and potential physical harm. In addition, the court noted that Abraham had filed information related to the cases on the public docket, and that the court used that information to locate the cases discussed in her sanctions motion.
The court therefore found no reason to seal citation-related information concerning public judicial proceedings. It referred generally to decisions discussing the First Amendment right of public access to judicial documents.
Outcome
The court denied Abraham’s request to seal docket entry 692. The order did not state that the request was denied with or without prejudice.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.