Rodenburg v. Chrismatic Studios Corp.
- Valerie Caproni
- 1:21-cv-07308
- U.S. District Court · Southern District of New York
- 2
In Rodenburg v. Charismatic Studios Corp., Judge Caproni denied without prejudice the parties’ request to seal their settlement agreement because they sought court enforcement jurisdiction.
The parties to the settlement, third parties whose privacy may be implicated, and members of the public seeking access to the settlement agreement.
What happened
In Rodenburg v. Charismatic Studios Corp., the parties agreed to settle the case and asked to file their settlement agreement under seal. They also asked the court to keep authority to enforce the agreement.
The court explained that documents relevant to the court’s work generally have a public right of access. Although privacy interests of third parties can support sealing, the court concluded that the settlement agreement was a judicial document because the parties asked the court to retain enforcement authority.
Judge Valerie Caproni denied without prejudice the request to seal the agreement. The parties may withdraw their request for the court to retain enforcement authority or file a new sealing request that makes the agreement generally public while protecting third-party confidentiality.
The detailed version
- Rodenburg v. Chrismatic Studios Corp. · No. 1:21-cv-07308
- Valerie Caproni
- July 21, 2022
Background
Patsy Rodenburg brought this action against Charismatic Studios Corp. d/b/a Michael Howard Studios and Gabrielle Berberich. On June 15, 2022, the parties agreed to settle the action. On July 14, 2022, they asked permission to file their settlement agreement under seal. Alternatively, they proposed filing a version that incorporated by reference an appendix containing terms they wanted to keep confidential. The parties also asked the court to retain jurisdiction, meaning authority to oversee and enforce the settlement agreement.
Court’s analysis
The court stated that judicial documents generally carry a presumptive public right of access. A judicial document is one filed with the court that is relevant to the court’s work and useful in the judicial process. Sealing requests must be reviewed carefully and skeptically, although privacy interests of third parties can justify sealing.
Because the parties asked the court to retain jurisdiction to enforce the settlement agreement, the court held that the agreement was a judicial document subject to public access. The court therefore did not approve the proposed sealing arrangement.
Ruling
Judge Valerie Caproni denied without prejudice the motion to file the settlement agreement under seal. The parties may either withdraw their request that the court retain jurisdiction to enforce the agreement or file a new sealing request proposing narrower sealing that makes the agreement generally public while protecting the confidentiality of third parties.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.