Lee v. Seed Public Charter School of Washington, Dc
Civil Action No. 2018-2786
| D.D.C. | Oct 15, 2021Background
- Plaintiff Chante Lee, on behalf of her minor son M.L., sued Seed Public Charter School alleging violations of the Rehabilitation Act and common‑law torts based on bullying/violence while M.L. attended the school in 2016–2017.
- The parties reached a settlement and, because it involved a minor, sought mandatory court approval under D.C. Code § 21‑120(a).
- The parties jointly filed the motion for approval and the Settlement Agreement (with Addendum) under seal and then moved for leave to maintain those filings under seal.
- The Court applied the common‑law right of public access and the D.C. Circuit’s six‑factor Hubbard balancing test to decide whether the settlement motion and agreement are judicial records that should remain sealed.
- The Court held the filings are judicial records, found strong public‑interest reasons favoring disclosure (public charter school, settlements involving minors, and judicial approval), and denied the Motion to Seal.
- The Court allowed limited redaction of personal identifying information (e.g., minor’s full name, plaintiff’s SSN), ordered the parties to submit proposed redacted versions and a motion to approve redactions by October 22, 2021, and kept the current sealed filings sealed pending that submission.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the joint motion and settlement agreement are "judicial records" subject to the presumption of public access | The parties did not contest that they are judicial records; they moved directly to sealing | Same | Yes — filings were intended to influence the Court and thus are judicial records. |
| Whether the Hubbard factors justify sealing the settlement motion and agreement | Parties argued there was no public need for access; confidentiality clause and personal/sensitive information (minor’s name, SSN) justify sealing | Same (both parties sought sealing) | No — balancing favored disclosure: factors 1 and 6 strongly favored public access; other factors only moderately weighed against disclosure. |
| Whether limited redactions are appropriate | Parties asked for sealing but acknowledged privacy concerns for personal identifiers | Same | Yes — Court denied blanket sealing but authorized narrowly tailored redactions of personal identifying information and required submission of proposed redactions for court approval. |
Key Cases Cited
- MetLife, Inc. v. Fin. Stability Oversight Council, 865 F.3d 661 (D.C. Cir. 2017) (recognizing strong common‑law right of public access to judicial records)
- CNN v. FBI, 984 F.3d 114 (D.C. Cir. 2021) (documents filed to influence a judge are judicial records; access is not absolute)
- In re Leopold, 964 F.3d 1121 (D.C. Cir. 2020) (explaining Hubbard balancing and requirement that sealing be justified by justice)
- United States v. Hubbard, 650 F.2d 293 (D.C. Cir. 1980) (articulating six‑factor test for sealing judicial records)
- EEOC v. Nat'l Children's Ctr., Inc., 98 F.3d 1406 (D.C. Cir. 1996) (compelling public interest in disclosure where documents involve alleged wrongdoing at institutions serving children)
- In re Fort Totten Metrorail Cases, 960 F. Supp. 2d 2 (D.D.C. 2013) (denying sealing of minor settlement documents but permitting limited redactions)