Ingber v. New York University
- Loretta Preska
- 1:23-cv-10023
- U.S. District Court · Southern District of New York
- 4
In Ingber v. New York University, Judge Preska granted NYU’s unopposed motion to seal unredacted dismissal materials containing non-party students’ disciplinary information.
New York University and the non-party students whose disciplinary information appeared in the materials; the order also governs public access to those court filings.
What happened
In Ingber v. New York University, NYU asked to file unredacted versions of its memorandum supporting its motion to dismiss and a declaration under seal. The request was unopposed.
The court said the privacy interests of non-party students involved in disciplinary proceedings outweighed the usual presumption that court records should be public. It also found that NYU’s proposed redactions were limited and narrowly tailored.
Judge Loretta A. Preska granted NYU’s motion to file the unredacted memorandum and declaration under seal. NYU may file redacted versions electronically, and the clerk was directed to close docket entry 41.
The detailed version
- Ingber v. New York University · No. 1:23-cv-10023
- Loretta Preska
- Mar. 25, 2024
Background
New York University asked the court to allow it to file under seal the unredacted versions of its memorandum of law supporting its motion to dismiss and the declaration of Jason Pina. NYU’s letter motion was unopposed.
Legal standard
The court explained that judicial documents carry a strong presumption of public access. A court may nevertheless seal documents when specific findings show that sealing is necessary to protect a higher value and the order is narrowly tailored. Privacy interests, especially those of innocent third parties, are one interest that may outweigh public access.
Court’s analysis
The court found that the privacy interests of non-party students who were subject to disciplinary proceedings outweighed the presumption of public access to the unredacted materials. The students had not initiated or participated in the lawsuit, and the court considered their disciplinary records sensitive information that did not need to be disclosed publicly at that stage to decide the case.
The court also found that NYU’s proposed redactions covered only a few sentences in the declaration and memorandum. It concluded that the proposal was narrow enough to protect the students’ privacy without unnecessarily limiting public access to court records.
Ruling
The court granted NYU’s unopposed motion to file under seal the unredacted versions of its memorandum supporting its motion to dismiss and Jason Pina’s declaration. NYU may file redacted versions through the court’s electronic filing system. The clerk was directed to close docket entry 41. Judge Loretta A. Preska signed the order on March 25, 2024.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.