Wilder v. Hoiland
- P. Castel
- 1:22-cv-01254
- U.S. District Court · Southern District of New York
- 4
In Wilder v. Hoiland, Judge Castel approved redactions to two exhibits containing third-party information in a copyright case.
Esther Wilder and Sarah Hoiland, as well as third parties whose information appeared in the two exhibits; the order approved redactions to those exhibits.
What happened
In Wilder v. Hoiland, Esther Wilder asked the court to limit public access to materials filed with the parties’ summary-judgment motions in a copyright-infringement dispute involving Sarah Hoiland.
Wilder sought redactions in two exhibits containing personal information about third-party faculty and a colleague. She also asked to keep four exhibits about a confidential City University of New York research-misconduct process under seal, arguing that the information was private and unrelated to the copyright issues.
Judge P. Kevin Castel approved the proposed redactions to Exhibit 5 and Exhibit 11 of Hoiland’s declaration. The order shown does not expressly state how the court ruled on the separate request to seal the four exhibits from the Cohen declaration.
The detailed version
- Wilder v. Hoiland · No. 1:22-cv-01254
- P. Castel
- Apr. 27, 2023
Background
Esther Wilder filed a letter motion concerning exhibits that Sarah Hoiland had referenced in briefing on the parties’ summary-judgment motions. The underlying dispute concerns alleged copyright infringement and Hoiland’s asserted defenses of implied consent and fair use.
Wilder asked to redact limited portions of Exhibits 5 and 11 to Hoiland’s declaration. The proposed redactions covered names, discussions, and evaluations involving third-party faculty enrolled in a program conducted under a National Science Foundation grant, as well as discussion of Hoiland’s comments about a colleague. Wilder argued that this information was private, irrelevant to the copyright issues, and concerned people who were not parties to the case.
Wilder also asked that four exhibits to the declaration of Guy Cohen—Exhibits 2, 4, 5, and 6—remain entirely under seal. According to the letter, those documents concerned a confidential City University of New York process for investigating research-misconduct complaints. Wilder argued that disclosure could undermine the confidentiality of that process and discourage future complainants and witnesses from participating. The letter also argued that the documents were only tangentially related to Hoiland’s copyright defenses.
Legal Standard Described in the Filing
The filing explained that documents submitted in connection with summary-judgment motions generally carry a presumption of public access under common-law and constitutional principles. It stated that privacy and confidentiality interests may overcome that presumption, particularly when the material is not central to the court’s decision.
Ruling
The court’s order states: “The proposed redaction to Exhibit 5 and Exhibit 11 Hoiland are approved.” Judge P. Kevin Castel therefore approved the proposed redactions to those two exhibits.
The text provided does not include an express ruling on Wilder’s separate request to seal Exhibits 2, 4, 5, and 6 to the Cohen declaration. It also does not state any ruling on the parties’ summary-judgment motions themselves.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.