Combs v. The Twins Group, Inc., 3:16-cv-00295

Plaintiff Aaron M. Combs brought an FLSA action against The Twins Group, Inc.
Defendant filed an unopposed motion for leave to file a joint motion for approval of a settlement under seal, citing a confidentiality provision in the parties’ settlement.
The motion offered only the settlement confidentiality clause as the basis for sealing the court filing.
The magistrate judge relied on Sixth Circuit precedent distinguishing secrecy in discovery from sealing judicial records, emphasizing public access to court filings.
The court noted the heavy burden to justify sealing: showing compelling reasons, analyzing documents item-by-item, and narrowly tailoring any seal.
The court denied Defendant’s motion without prejudice, permitting refiling with adequate justification.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether parties may file settlement terms under seal based on a confidentiality provision	Combs did not oppose filing under seal; no affirmative argument for sealing presented by plaintiff	The Twins Group argued the settlement confidentiality provision justified sealing the joint filing	Motion to file under seal denied without prejudice; defendant failed to meet Sixth Circuit’s heavy burden to justify sealing
Standard required to seal court filings	Public entitled to assess merits; access favored	Secrecy acceptable in discovery but not for court record; must show compelling reasons, narrow tailoring	Court applied Sixth Circuit standard requiring detailed, document-by-document justification; defendant did not provide it
Effect of lack of opposition to sealing	No argument that lack of opposition eliminates court’s duty to assess sealing	Defendant asserted joint agreement and lack of opposition supported filing under seal	Court held lack of opposition is insufficient; movant still bears burden to justify sealing
Whether similar requests in FLSA context justify sealing	N/A	Defendant relied on settlement confidentiality as categorical basis in FLSA case	Court cited precedent denying similar FLSA sealing request and denied motion without prejudice

Rudd Equip. Co., Inc. v. John Deere Constr. & Forestry Co., 834 F.3d 589 (6th Cir. 2016) (distinguishing discovery secrecy from sealing the court record; articulating sealing burden)
Shane Grp., Inc. v. Blue Cross Blue Shield of Mich., 825 F.3d 299 (6th Cir. 2016) (public access presumption and requirement that sealing be narrowly tailored and justified)
Lee v. Asurian Ins. Servs., Inc., 206 F. Supp. 3d 1307 (M.D. Tenn. 2016) (denying a similar request to seal settlement terms in an FLSA case)