Paulino-Santos v. Metropolitan Transit Authority

Background

The defendants moved to seal materials filed in the case. The materials included Exhibits 1–5 to the declaration identified as the “Goodell Decl.” The defendants sought to keep Exhibits 4 and 5 sealed. Those exhibits contained charts showing, month by month for 2022 and 2023, the number of Access-A-Ride registrants, potential applicants, and eligibility determinations.

Court’s Analysis

The court explained that Exhibits 4 and 5 were “judicial documents,” meaning court-filed materials to which the public generally has a strong right of access. The court stated that a protective order does not eliminate that public-access presumption once materials become judicial documents.

The court also considered the Metropolitan Transportation Authority’s status as a public benefit corporation chartered by the New York State Legislature, and New York City Transit Authority’s status as its subsidiary. Because the data concerned the operation of public transit services for individuals with disabilities, the court found that the value of public disclosure was substantial and the privacy interests were minimal.

The defendants argued that disclosure could cause competitive harm by making it harder to negotiate future contracts with third parties. The court found that this assertion was conclusory and did not adequately explain why the materials were commercially sensitive or how disclosure would cause serious injury.

Ruling

The court granted in part and denied in part the motion to seal. Under the court’s individual rules, the parties could substitute Exhibits 1–3 with new redacted versions. The court denied the request to seal Exhibits 4 and 5, directed the Clerk of Court to unseal ECF Nos. 60-4 and 60-5, and directed the Clerk to terminate ECF No. 71.