Court Refuses to Seal Records Showing Non-Party Names and Addresses

On May 27, 2025, Justice Reed of the New York County Commercial Division issued a decision in Schneider v. Pine Mgt., Inc., 2025 NY Slip Op. 50855(U), refusing to seal court records showing non-party names and addresses, explaining:

Under New York law, there is a clear presumption that the public is entitled to access to judicial proceedings and court records. However, a court is empowered to seal or redact court records upon a showing of good cause.

Section 216.1(a) of the Uniform Rules for Trial Courts provides:

(a) except where otherwise provided by statute or rule, a court shall not enter an order in any action or proceeding sealing the court records, whether in whole or in part, except upon a written finding of good cause, which shall specify the grounds thereof. In determining whether good cause has been shown, the court shall consider the interests of the public as well as the parties. Where it appears necessary or desirable, the court may prescribe appropriate notice and an opportunity to be heard.

In the business context, courts permit records to be sealed when trade secrets are involved or when disclosure of information contained in documents could threaten a business’s competitive advantage.

Here, there is no threat of trade secrets or competitive confidential information disclosure. Although the parties submit that permanent sealing is required to protect the confidentiality of nonparty entities, it has been held previously that names and addresses are not confidential materials subject to protection.

In this instance, granting an order sealing the subject records does not comport with or overcome the broad presumption of public entitlement to judicial proceedings and court records. For these and the foregoing reasons, defendants’ requests to seal summary judgment opposition documents is denied.

(Internal quotations and citations omitted).

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