Macalou v. First Unum Life Insurance Company

Background

Anticia Macalou brought this action under the Employee Retirement Income Security Act of 1974 to seek long-term disability benefits under an employee benefits plan administered by First Unum Life Insurance Company. She alleged that she was disabled under the plan because of major depressive disorder, anxiety disorder, post-traumatic stress disorder, and attention deficit/hyperactivity disorder.

The parties agreed to try the case before the court based on a stipulated administrative record. On February 28, 2024, the court provisionally allowed Macalou’s request to seal the complaint, administrative record, and briefing materials, on the condition that she file redacted versions within thirty days. The court found that the versions she filed redacted nearly all of the documents.

Court’s Analysis

The court held that the basic facts underlying the action were not entitled to sealing because the common-law presumption of public access outweighed Macalou’s privacy interest. The court noted that the complaint had already been publicly available for approximately fourteen months. It also held that information about the medical conditions forming the basis of Macalou’s alleged disability could not be redacted.

The court distinguished unrelated medical information and personal information, such as Social Security numbers, account numbers, email addresses, phone numbers, and personal addresses. Those categories could be redacted if the redactions were narrowly tailored. The court further stated that the sealed administrative record should contain no redactions because significant redactions prevented the court from reviewing portions of that record.

Ruling

Judge P. Castel directed Macalou to file, by April 19, 2024, narrowly redacted versions of the administrative record and the specified trial briefs, proposed findings, responses, opposition papers, reply briefs, and exhibits. The redactions were limited to medical information unrelated to the conditions at issue and personal information. The parties were required to file an unredacted administrative record under seal by the same date. The court also respectfully requested that the Clerk of Court unseal the complaint filed at ECF 1.

This order addressed sealing and public access to court filings. It did not decide whether Macalou was entitled to the claimed disability benefits.