Catania v. United Federation of Teachers

Background

On October 17, 2022, Magistrate Judge Willis entered a report and recommendations. Plaintiffs had fourteen days to file objections. Plaintiffs’ counsel contacted the court by email to request additional time and filed a motion to seal those communications.

Extension of Time

The court granted plaintiffs’ request for an extension. Any objections to the report and recommendations had to be filed by November 14, 2022.

Sealing Analysis

The court explained that judicial documents—materials relevant to the court’s work and useful in the judicial process—are generally presumed to be accessible to the public. Courts must balance that presumption against legitimate reasons for withholding documents, including privacy interests.

The court found that the communications and attachments were judicial documents because they were filed in connection with plaintiffs’ request for more time to object. It nevertheless found that the presumption of public access was modest because the materials mainly discussed plaintiffs’ counsel’s personal circumstances rather than legal issues in the case. The court also found substantial reasons against disclosure because the materials contained personal information whose public release would unnecessarily intrude on counsel’s privacy.

Ruling

Judge Gregory H. Woods granted plaintiffs’ application for an extension of time to object to the report and recommendations. The court also granted plaintiffs’ application to seal communications between plaintiffs’ counsel and the court from October 28 through October 31, 2022, and all attachments to those emails. The clerk was directed to terminate the motion at Docket No. 93.