Wood v. Mike Bloomberg 2020, Inc.
- Laura Swain
- 1:20-cv-02489
- U.S. District Court · Southern District of New York
- 3
In Wood v. Mike Bloomberg 2020, Inc., Judge Swain ordered some exhibits publicly refiled and allowed narrow privacy redactions for others.
The plaintiffs and Mike Bloomberg 2020, Inc.; third-party Campaign volunteers and employees whose non-public information appeared in certain exhibits; and individuals whose home addresses or telephone numbers appeared in other exhibits.
What happened
Wood v. Mike Bloomberg 2020, Inc. came before the court on three requests to seal or redact exhibits filed by the plaintiffs and the Campaign. The requests arose from filings related to the Campaign’s motion to decertify a wage-related collective action and the parties’ partial summary-judgment motions.
The court ordered the plaintiffs to refile their exhibits without redactions because neither side supported continued secrecy. It allowed the Campaign to keep proposed redactions in five exhibits containing home addresses or telephone numbers and two exhibits containing non-public information about Campaign volunteers and employees. The Campaign also had to refile another exhibit without redactions.
Judge Swain explained that court filings are generally presumed open to the public and that redactions must be narrowly tailored. The order granted the Campaign’s specified redaction requests, directed public refiling of the other exhibits, and resolved docket entries 440, 450, and 459.
The detailed version
- Wood v. Mike Bloomberg 2020, Inc. · No. 1:20-cv-02489
- Laura Swain
- Apr. 12, 2024
Background
The court considered three applications to seal or redact court exhibits: two filed by the plaintiffs and one filed by Mike Bloomberg 2020, Inc., which the opinion calls the “Campaign.” The plaintiffs had filed redacted exhibits supporting their opposition to the Campaign’s motion to decertify the Fair Labor Standards Act collective action and supporting their motion for partial summary judgment. The plaintiffs stated that they did not believe the redacted materials met the high standard for sealing, and the Campaign did not object to public filing of those documents.
The Campaign asked to file seven exhibits to its motion for partial summary judgment with redactions: Exhibits QQ, VV, III, OOO, PPP, 9, and 12. It also filed Exhibit B with redactions because the plaintiffs had marked that document “Confidential.” Neither side requested continued sealing of Exhibit B.
Court’s Analysis
The court explained that any sealing or redaction of a court filing must be narrowly tailored to serve the reason justifying secrecy and must be consistent with the presumption that judicial documents are publicly accessible.
Exhibits QQ, VV, III, OOO, and PPP contained personally identifying information, including home addresses and telephone numbers. The court granted the Campaign’s request to file those exhibits with its proposed redactions. Exhibits 9 and 12 contained non-public information about third-party Campaign volunteers and employees. Because the court had previously allowed the same documents to be filed with redactions and recognized the privacy interests of third parties, it also granted the Campaign’s request to use the proposed redactions in Exhibits 9 and 12.
Ruling
The court directed the plaintiffs to refile the exhibits listed in docket entries 440 and 459 on the public docket without redactions. It granted the Campaign’s requests to file Exhibits QQ, VV, III, OOO, PPP, 9, and 12 with the proposed redactions. Because no party requested continued sealing of Exhibit B, the court directed the Campaign to refile Exhibit B publicly without redactions. Judge Laura Taylor Swain stated that the order resolved docket entries 440, 450, and 459.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.