Lenzo v. City of New York
- Jesse Furman
- 1:21-cv-00306
- U.S. District Court · Southern District of New York
- 6
In Lenzo v. City of New York, Judge Furman denied Tory Lenzo’s request to remove the case from public records or redact his name.
Tory Lenzo’s request to remove the case from public records or redact his name was denied; the order leaves the court’s stated presumption of public access in place.
What happened
In Lenzo v. City of New York, Tory Lenzo asked the court to remove the case from public records or redact his name in online searches and at the courthouse.
The court explained that judicial records are generally presumed to be open to the public. It found that Lenzo had not shown that sealing the records or redacting his name was necessary to protect an important interest and narrowly limited to that purpose.
Judge Furman denied Lenzo’s request and directed the Clerk of Court to mail him a copy of the order.
The detailed version
- Lenzo v. City of New York · No. 1:21-cv-00306
- Jesse Furman
- Sept. 14, 2023
Background
On September 13, 2023, Tory Lenzo sent a letter to the Chief Judge asking the court to “totally remove[]” the case from public records or redact his name from public court searches, online records, and physical courthouse records. The Chief Judge referred the request to Judge Furman because the request concerned a case assigned to him.
Legal standard
The court stated that judicial documents are presumed to be immediately accessible under both the common law and the First Amendment. Before sealing judicial documents, a court must separately evaluate the documents under both standards and decide whether sealing is justified and narrowly tailored to protect the interests supporting it.
Court’s reasoning
The court held that generalized concerns about adverse publicity, privacy, embarrassment, and confidentiality were not enough to overcome the presumption of public access. It stated that Lenzo had not explained what specific privacy interests he had or how sealing or redaction would be narrowly tailored to protect those interests.
Disposition
The court denied Lenzo’s request. It also directed the Clerk of Court to mail Lenzo a copy of the order.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.