Macalou v. First Unum Life Insurance Company

Background

Macalou moved for reconsideration of an earlier order concerning public access to the administrative record in her challenge to First Unum Life Insurance Company’s denial of long-term benefits. The earlier order required her to file the administrative record on the public docket, allowing redactions for her unrelated medical information and personal information. Macalou argued that the entire record should instead be filed under seal because it contained confidential medical information. First Unum did not take a position on the motion.

The parties had agreed that the case would be tried to the court under Federal Rule of Civil Procedure 52(a), based on the administrative record. The court stated that its factual findings would rely on that record.

Court’s Analysis

The court held that the administrative record was a “judicial document,” meaning a court filing relevant to the court’s adjudication of the case. Judicial documents carry a common-law presumption of public access, and the court said the presumption was strongest here because the administrative record would provide the basis for all of the court’s findings of fact. Public access, the court explained, promotes accountability and public confidence in the administration of justice.

The court found Macalou’s request to seal the entire record “vastly overbroad and unwarranted.” It noted that the record included materials such as a blank disability claim form, descriptions of job duties, an employer’s group policy, compensation information, a corporate-information form, and social-media postings about employment. The court reasoned that information about employment history, workplace relationships, job responsibilities, and performance would not necessarily reveal the medical information Macalou sought to protect.

The court also stated that the party seeking to seal materials—not the court—had the responsibility to identify personal medical information that could overcome the presumption of public access. Counsel’s assertion that narrowly redacting the record would be burdensome or not a useful use of time was not a sufficient reason to deny public access to the entire record.

Disposition

The court adhered to its prior order and DENIED Macalou’s motion for reconsideration. The opinion did not decide the underlying dispute over whether First Unum properly denied Macalou’s long-term benefits.