Johnson v. The Hartford
- Philip Halpern
- 7:22-cv-06394
- U.S. District Court · Southern District of New York
- 2
In Johnson v. The Hartford, Judge Halpern granted The Hartford’s request to seal the administrative record because it contains extensive medical and identifying information.
Johnson’s medical and personal information, the parties’ access to the administrative record, and public access to Doc. 17 and its attachments.
What happened
Johnson v. The Hartford is an ERISA case involving an administrative record that The Hartford sought to file without redactions.
The Hartford said the more-than-2,100-page record contains medical information, diagnoses, treatment details, a Social Security number, a birth date, and other personal information. It argued that sealing the entire record was the narrowest practical way to protect Johnson’s privacy.
Judge Philip M. Halpern granted the application. He allowed The Hartford to file the administrative record under seal, limited access to the parties and the Court, directed the Clerk to keep the summary docket available, and terminated the pending motion sequence at Doc. 16.
The detailed version
- Johnson v. The Hartford · No. 7:22-cv-06394
- Philip Halpern
- Dec. 12, 2022
Background
The Hartford asked to file the administrative record in this ERISA action under seal. The record was described as spanning more than 2,100 pages.
Request to Seal
The Hartford argued that the record contains extensive information about Johnson’s medical conditions, diagnoses, and treatment that may constitute protected health information under the Health Insurance Portability and Accountability Act. It also stated that the documents contain Johnson’s Social Security number, date of birth, and other personally identifiable information. The request asserted that redacting the record would be extremely burdensome and that public disclosure could seriously harm Johnson’s privacy. The Hartford therefore argued that filing the unredacted record under seal was the least restrictive available alternative.
Ruling
Judge Philip M. Halpern granted the application. The Court granted The Hartford leave to file the administrative record, identified as Doc. 17, under seal. The Clerk was directed to seal Doc. 17 and its attachments, allow access only to the parties and the Court, retain the summary docket, and terminate the motion sequence pending at Doc. 16.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.