John Doe v. City Of New York
- P. Castel
- 1:22-cv-02690
- U.S. District Court · Southern District of New York
- 12
In John Doe v. City of New York, Judge Castel granted Doe’s motion to seal narrowly redacted expert-report material protecting his identity and safety.
John Doe’s identity and safety, the defendants’ access to the sealed expert report, and the public’s access to the unredacted document.
What happened
In John Doe v. City of New York, John Doe asked to publicly file a redacted version of his expert’s report while keeping the unredacted report sealed. The report concerned Doe’s work as a confidential informant and information about his case.
Doe’s lawyer said the report contained sensitive information that could reveal Doe’s identity and endanger him. The lawyer also said some material was covered by a confidentiality and protective order. Defense counsel was contacted about the request but had not responded.
Judge Castel granted the motion. The court found that the proposed redactions were narrowly tailored to protect information that could reveal Doe’s identity and place him in danger. The clerk was directed to keep the unredacted report under seal and publicly file the redacted version.
The detailed version
- John Doe v. City Of New York · No. 1:22-cv-02690
- P. Castel
- Apr. 1, 2024
Background
John Doe asked the court to allow a redacted version of his expert’s report to be filed publicly and to keep the unredacted version under seal. The report had previously been filed under seal in connection with the defendants’ motion to preclude Doe’s expert.
The request stated that the report contained highly sensitive information about Doe and his work as a confidential informant. It also contained information designated confidential under a confidentiality and protective order. According to Doe’s submission, disclosure could reveal his identity and create a safety risk. Doe’s identity had been sealed and protected since the case was filed.
The expert report evaluated the New York City Police Department’s practices in handling confidential informants. The expert expressed opinions that Defendant Richard Roe did not follow proper police practices, including practices concerning documentation of contacts with Doe, use of a personal cellphone, and the frequency of communications with Doe. These opinions were included in the report submitted for sealing purposes; the court’s order did not decide whether those opinions were correct.
Court’s Analysis
The court found that the proposed redactions were appropriately narrow. It determined that the information to be redacted could reveal Doe’s identity and place him in danger because of the nature of his work as a confidential informant.
Ruling
Judge P. Castel granted Doe’s motion to seal. The clerk was directed to terminate the motions at ECF Nos. 143 and 154, maintain the unredacted document at ECF No. 144-2 under seal, and publicly file the redacted version attached to the order at ECF No. 154-1.
Read the full 12-page opinion on CourtListener, the free public archive maintained by the Free Law Project.