Lewis v. Laz Parking Ltd., LLC

District Court, S.D. New York·Decided April 23, 2025·No. 1:25-cv-02341·Unknown

Opinion

VOM. OVINE DOCUMENT UNITED STATES DISTRICT COURT ELECTRONICALLY FILED SOUTHERN DISTRICT OF NEW YORK I DATE FILED:__ 4/23/2025 ANDRE LEWIS, Plaintiff,

LAZ PARKING LTD., LLC, et al., = Defendants.

MARGARET M. GARNETT, United States District Judge: Plaintiff, who is appearing pro se, brings this action under the court’s diversity of citizenship jurisdiction, asserting claims of breach of contract, defamation, and tortious interference with business relationships. Dkt. No. 1 “Complaint” or “Compl.”). By order dated April 17, 2025, the Court granted Plaintiff's request to proceed in forma pauperis (“IFP”), that is, without prepayment of fees..! Dkt. No. 12. For the reasons set forth below, the Court: (1) denies Plaintiff's motion to proceed under seal (Dkt. No. 8); (2) directs service on Laz Parking, Ltd., LLC (“Laz Parking”); and (3) directs Laz Parking to provide an address at which Juan Irizarry may be served. DISCUSSION I. MOTION TO SEAL Plaintiff has filed a motion to seal this action. Dkt. No. 8. Both the common law and the First Amendment protect the public’s night of access to court documents. See Nixon v. Warner Comms., Inc., 435 U.S. 589, 597-99 (1978); Hartford Courant Co. v. Pellegrino, 380 F.3d 83, 91-92 (2d Cir. 2004). This right of access is not absolute, and “the decision as to access [to judicial records] is one best left to the sound discretion of the trial court, a discretion to be exercised in light of the relevant facts and circumstances of the particular case.” Nixon, 435 U.S. at 599 (footnote omitted). The Second Circuit has set forth a three-part analysis to determine whether, under the common law, a document relating to a lawsuit should be made available to the public. See Lugosch v. Pyramid Co., 435 F.3d 110, 119-20 (2d Cir. 2006).

! The application to proceed in forma pauperis (“IFP”) that Plaintiff filed with the complaint was inadequate. See Dkt. No. 4. By order dated March 24, 2025, the Honorable Laura Taylor Swain, in her capacity as Chief Judge, directed Plaintiff to pay the filing fees or submit an amended IFP application. Dkt. No. 9. Plaintiff filed an amended IFP application on April 8, 2025. Dkt. No. 11.

First, the Court must determine whether the document at issue is indeed a “judicial document,” to which the public has a presumptive right of access. Jd. at 119. Complaints are considered judicial documents for the purpose of this analysis. Bernstein v. Bernstein Litowitz Berger & Grossman LLP, 814 F.3d 132, 139-40 (2d Cir. 2016) (all pleadings, including a complaint, “are judicial records subject to a presumption of public access”). The same 1s true with respect to a court’s own decisions and orders. See Hardy v. Equitable Life Assurance Soc’y of the United States, 697 F. App’x 723, 725—26 (2d Cir. 2017); Ferrand v. Credit Lyonnais, 106 F. Supp. 3d 452, 455 (S.D.N-Y. 2015). Second, the Court must determine the weight of the presumption of access. “It is plain that a complaint is a judicial document to which the presumption of access attaches . . . because the complaint ‘is highly relevant to the exercise of Article III judicial power’ and the complaint “invokes the powers of the court, states the causes of action, and prays for relief.’” Haider v. Geller & Co. LLC, 457 F. Supp. 3d 424, 427 (S.D.N.Y. 2020) (quoting Bernstein, 814 F.3d at 142). Moreover, “[u|nder the First Amendment analysis, complaints have historically been publicly accessible by default and such access allows the public to ‘understand the activity of the federal courts, enhances the court system’s accountability and legitimacy, and informs the public of matters of public concern.’” Jd. (quoting Bernstein, 814 F.3d at 141). “Notwithstanding this presumption of access, portions of the complaint may be kept under seal if ‘countervailing factors in the common law framework or higher values in the First Amendment framework,’” including the attorney-client privilege. Jd. (quoting Lugosch, 435 F.3d at 124 (internal quotation marks omitted)). Third, “the court must balance competing considerations against” the presumption of access. Lugosch, 435 F.3d at 120 (internal quotation marks and citation omitted). “Such countervailing factors include but are not limited to the danger of impairing law enforcement or judicial efficiency and the privacy interests of those resisting disclosure.” Jd. (internal quotation marks and citation omitted). Generally, the privacy interests considered are those of innocent third parties. See United States v. Amodeo, 71 F.3d 1044, 1050-51 (2d Cir. 1995). Here, the crux of Plaintiff's claims in this action is that he entered into a settlement agreement with Defendant Laz Parking, which included non-disparagement and confidentiality provisions, and that Defendants have breached those provisions and caused Plaintiff professional and reputational harm. In his motion, Plaintiff requests that this case be sealed “to prevent further harm to Plaintiff's reputation and career prospects.” Dkt. No. 8 at 1. He requests that access to “all filings, exhibits, and court records” be restricted to the parties, their counsel, and the court, and that the Court prevent disclosure of “case details” to third parties, “including the media, industry professionals, and the general public.” Jd. He maintains that public access to documents in this case “would further damage [his] professional reputation and business interests by exposing sensitive allegations and information to potential employers, clients, and industry stakeholders.” Jd. at 2. Plaintiff's broad sealing request is denied. The Court finds that the documents submitted in this case are “judicial document{|s],” to which the public is presumed to have a right of access. See Bernstein, 814 F.3d at 139-40. Furthermore, the contents of Plaintiff's submissions, taken

as a whole, are not sufficiently extraordinary and, consequently, do not outweigh the strong presumption in favor of public access to them. As for the Complaint and Plaintiff's other motions, the presumption of access may only be overcome by countervailing factors. Plaintiff seeks to place these documents under seal for privacy reasons and to protect his professional reputation. Courts have repeatedly held that the potential for a negative impact on a party’s future business or social status does not outweigh the presumption of access. See, e.g., Saadeh v. Kagan, No. 20-CV-01945 (PAE) (SN), 2021 WL 965334, at *2 (S.D.N.Y. Mar. 15, 2021) (holding that “[t]he potential for a negative impact on a party’s future business or social status does not outweigh the presumption of access” and collecting cases); Zabolotsky v. Experian, No. 19-CV-11832 (GHW), 2021 WL 106416, at *3 (S.D.N.Y. Jan. 12, 2021) (denying motion to seal case file “for the sake of [plaintiff's] livelihood and professional and personal reputation” because “[i]t is well-settled that neither generalized concerns of adverse publicity nor the possibility of future adverse impact on employment outweigh the presumption of public access” (internal quotation marks and citation omitted)): Badinelli v. Tuxedo Club, No. 15-CV-06273 (VLB), 2018 WL 6411275, at *2 (S.D.N.Y. Dec. 6, 2018) (refusing to seal case records, finding plaintiff's “interest in privacy, professional reputation, and earning capacity” did not “outweigh the interest in public access to the record”): Under Seal v. Under Seal, 273 F. Supp. 3d 460

Free access — add to your briefcase to read the full text and ask questions with AI

Lewis v. Laz Parking Ltd., LLC, (S.D.N.Y. 2025).

Lewis v. Laz Parking Ltd., LLC (Lewis v. Laz Parking Ltd., LLC) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Nixon v. Warner Communications, Inc.
435 U.S. 589 (Supreme Court, 1978)
United States v. Amodeo
71 F.3d 1044 (Second Circuit, 1995)
Hartford Courant Co. v. Pellegrino
380 F.3d 83 (Second Circuit, 2004)
Lugosch v. Pyramid Co. of Onondaga
435 F.3d 110 (Second Circuit, 2006)
Meilleur v. Strong
682 F.3d 56 (Second Circuit, 2012)
Walker v. Schult
717 F.3d 119 (Second Circuit, 2013)
Ferrand v. Credit Lyonnais
106 F. Supp. 3d 452 (S.D. New York, 2015)
Under Seal v. Under Seal
273 F. Supp. 3d 460 (S.D. New York, 2017)