Robinson v. De Niro
- Lewis Liman
- 1:19-cv-09156
- U.S. District Court · Southern District of New York
- 4
In Robinson v. De Niro, Judge Parker granted Defendants’ motion to seal sensitive personal information and required revised exhibits and transcripts.
The order affected Defendants’ filing obligations and the public’s access to the specified exhibits. It protected the privacy interests of parties, witnesses, and family members whose medical, identifying, family, or financial information appeared in the exhibits.
What happened
In Robinson v. De Niro, Defendants asked to keep certain exhibits supporting their sanctions motion sealed or to file redacted versions. The court had previously found that only one medical record warranted continued sealing and allowed Defendants to renew their request with narrower redactions for other exhibits.
The court explained that judicial documents generally are presumed open to the public. It found that the proposed redactions covered medical information, birth dates, addresses, family matters, and financial information—details in which individuals have important privacy interests. The court also found the redactions narrowly limited to that sensitive personal information.
Judge Katharine H. Parker granted Defendants’ amended motion to seal. Some exhibits were unsealed, while other exhibits remained sealed and had to be replaced with redacted versions by July 29, 2022. Defendants also had to file unredacted transcripts of specified audio recordings by that date.
The detailed version
- Robinson v. De Niro · No. 1:19-cv-09156
- Lewis Liman
- July 26, 2022
Background
Defendants had filed a motion for sanctions supported by attorney declarations and numerous exhibits. They initially sought to file 25 exhibits under seal. After reviewing them, the court ordered some documents unsealed, found that Plaintiff’s medical record at ECF No. 198-4 warranted sealing, and allowed Defendants to seek narrowly tailored redactions for other documents.
Defendants then filed an amended motion seeking to file redacted versions of ECF Nos. 198-3, 198-5, 198-13, 198-15, 231-8, and 231-9. The proposed redactions covered sensitive medical information and other personal information concerning the parties, witnesses, and family members.
Legal standard
The common law and the First Amendment create a presumption that the public may access judicial documents. Judicial documents are materials submitted for the court’s consideration in connection with a motion for sanctions. To overcome that presumption, the court must make specific findings that sealing is necessary to protect important interests and that the proposed sealing is narrowly tailored—that is, limited to the information requiring protection.
Analysis
The court found that the proposed redactions protected significant privacy interests. The medical information included disease diagnoses and symptoms. Other proposed redactions covered birth dates, addresses, family information, and financial information. The court concluded that sealing this information was necessary to preserve the personal privacy interests of numerous individuals and that the proposed redactions were narrowly tailored because they covered only sensitive personal information.
Ruling
The court granted Defendants’ amended motion to seal. The documents at ECF Nos. 198-8, 198-10, 198-11, 198-16, 198-17, 198-18, 198-19, 231-1, 231-5, 231-6, and 231-14 were unsealed under the court’s July 13, 2022 order.
The documents at ECF Nos. 198-3, 198-4, 198-5, 198-13, 198-15, 231-2, 231-3, 231-4, 231-7, 231-8, 231-9, 231-10, 231-11, and 231-12 remained under seal. By July 29, 2022, Defendants had to file revised versions of ECF Nos. 198-3, 198-5, 198-13, 198-15, 231-8, and 231-9 containing the proposed redactions. Defendants also had to file unredacted transcripts of the recordings referenced at ECF Nos. 231-2, 231-3, 231-4, 231-7, 231-10, 231-11, and 231-12.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.