Johnson v. Tennyson
- Jesse Furman
- 1:22-cv-05683
- U.S. District Court · Southern District of New York
- 4
Johnson v. Tennyson: Judge Aaron granted in part and denied in part a motion to seal exhibits, requiring redacted filings.
Eric Johnson must file redacted versions of four exhibits. Defendants’ sensitive commercial information and the identifying information of nonparty individuals will be redacted, while the court did not approve sealing the exhibits in full.
What happened
In Johnson v. Tennyson, Eric Johnson asked to seal four exhibits filed for a damages hearing because defendants had marked them confidential. The exhibits included business emails about Amazing Paint Party’s partner and venue programs.
The court recognized the public’s right to inspect court records but also recognized defendants’ interest in protecting sensitive business information and the privacy of people not involved in the case. It found that sealing some information was justified, but sealing the entire exhibits was broader than necessary.
Judge Stewart D. Aaron granted in part and denied in part the motion. He ordered Johnson to file redacted versions by March 16, 2023, removing nonparty names and email addresses, the substance of the partner terms and conditions, and details about the venue program.
The detailed version
- Johnson v. Tennyson · No. 1:22-cv-05683
- Jesse Furman
- Mar. 9, 2023
Background
Plaintiff Eric Johnson moved to seal four exhibits submitted in connection with the inquest on damages. An inquest is a court proceeding used to determine damages. The exhibits had been produced by Defendants in an earlier civil action and designated confidential. They consisted of emails concerning Amazing Paint Party’s “Paint Party Partners Terms and Conditions,” the use of images for promotional purposes, and the Venue Partnership Program.
Court’s analysis
The court treated the exhibits as judicial documents because they were submitted in connection with the damages proceeding. Judicial documents generally carry a presumption of public access, meaning the public ordinarily may inspect and copy them. The court balanced that presumption against competing interests, including the protection of sensitive commercial information and the privacy of nonparty individuals.
The court found that protecting the commercial information in the partner terms and conditions and the details of the Venue Partnership Program justified sealing those portions. It also found that protecting the names and email addresses of people not involved in the case justified redacting that information. But the court concluded that sealing the entire four exhibits was not narrowly tailored to protect those interests.
Disposition
The court granted in part and denied in part Johnson’s motion to seal. It ordered Johnson to file redacted versions of the four exhibits no later than March 16, 2023. The redactions had to cover the names and email addresses of individuals communicating with Defendants, the substance of Amazing Paint Party’s “Paint Party Partners Terms and Conditions,” and the details of the Venue Partnership Program.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.