Loomis Sayles Trust Company LLC v. Citigroup Global Markets Inc
- Lorna Schofield
- 1:22-cv-06706
- U.S. District Court · Southern District of New York
- 3
Loomis Sayles Trust Co. v. Citigroup Global Markets: Judge Schofield denied sealing motions because no party overcame the strong presumption of public access.
Loomis Sayles Trust Co., LLC, Citigroup Global Markets, Inc., and public access to the specified court filings.
What happened
In Loomis Sayles Trust Co., LLC v. Citigroup Global Markets, Inc., Loomis Sayles and Citigroup asked to keep parts of filings related to Citigroup’s summary judgment motion confidential. The requests covered a telephone call, portions of letters, and other information designated confidential under the parties’ agreement.
The court explained that materials filed with a summary judgment motion are judicial records with a strong presumption of public access. Confidentiality designations and an agreement between the parties were not enough to overcome that presumption, and the parties did not provide sufficient reasons for sealing the materials.
Judge Lorna G. Schofield denied the parties’ motions to file under seal. The court directed the Clerk of Court to close the four sealing motions and unseal the specified documents.
The detailed version
- Loomis Sayles Trust Company LLC v. Citigroup Global Markets Inc · No. 1:22-cv-06706
- Lorna Schofield
- July 28, 2023
Background
Loomis Sayles filed three letter motions asking to file certain information under seal in connection with Citigroup’s converted motion for summary judgment. The requests concerned the entirety of a telephone call between Citigroup employees, portions of Loomis Sayles’s February 17, 2023, supplemental-briefing letter, and portions of Loomis Sayles’s July 18, 2023, request to supplement the summary judgment record. Loomis Sayles based the requests on the parties’ confidentiality agreement and Citigroup’s designation of information as confidential. The motions stated that Citigroup had the interest in confidential treatment, and Citigroup did not file the letters supporting sealing required by the court’s local rule.
Citigroup separately moved to seal portions of its July 25, 2023, response to Loomis Sayles’s request for additional supplemental briefing. Citigroup relied on the parties’ confidentiality designations but gave no further explanation. Loomis Sayles did not timely file a supporting letter.
Court’s Analysis
The court applied a three-step test for sealing judicial documents. First, it asked whether the materials were relevant to the court’s work and therefore subject to the public-access right. Second, it assessed the strength of the presumption of access. Third, it balanced that presumption against competing interests, such as privacy.
The court held that materials filed in connection with a summary judgment motion are judicial documents subject to a strong presumption of public access. Such materials should not remain sealed without compelling reasons. The court also explained that a confidentiality designation or a privately negotiated confidentiality agreement is not, by itself, enough to overcome the presumption.
Disposition
The court ordered that the parties’ motions to file under seal were denied because no party rebutted the strong presumption of public access and the information was not the type that supported sealing. Judge Lorna G. Schofield directed the Clerk of Court to close the motions at Dkt. Nos. 55, 64, 97, and 100, and to unseal the documents at Dkt. Nos. 57, 59, 66, 98, 101, 102, and 103.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.