Maheu v. Twitter, Inc.
1:25-cv-00836
S.D.N.Y.Jun 23, 2025Background
- Petitioner Jean-Phillippe Maheu sought to confirm an arbitral award granted in his favor against Twitter, Inc. after he was terminated in November 2022.
- The arbitration was conducted under a dispute resolution agreement and resulted in an award for Maheu, which he attached to his petition to confirm in federal court.
- Maheu initially requested the arbitral award be filed under seal, citing Twitter's desire for confidentiality; the court denied this as insufficient to overcome public access rights.
- The case was voluntarily dismissed before the award was publicly filed, and subsequently, The New York Times requested the award be unsealed.
- Twitter (now X Corp.) moved to seal the award, arguing the confidentiality of the arbitration, while Maheu requested redaction only of the award's dollar amount.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to seal arbitral award attached to a confirmation petition | Did not object to public filing; only sought redaction of award amount for privacy | Confidential arbitration and party agreement require sealing | Motion to seal denied; confidentiality alone does not override First Amendment right of public access |
| Whether confidentiality of arbitration is a 'higher value' justifying sealing | No assertion that this alone justifies sealing | FAA and prior caselaw support strong confidentiality in arbitration awards | Confidential nature alone is not a 'higher value' capable of overcoming public access rights |
| Whether to redact financial information, specifically the award amount | Requested redaction as a privacy measure | Supported redaction/sealing due to privacy | Without specific factual showing of harm, no basis for redaction given |
| Whether voluntary dismissal weakens the presumption of access | No argument to this effect | Argued presumption weaker since petition was dismissed pre-resolution | First Amendment right to access applies regardless of dismissal |
Key Cases Cited
- Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555 (U.S. 1980) (discussing foundational principle of public access to judicial proceedings)
- Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) (outlining standard for sealing judicial documents; need for specific, on-the-record findings)
- Courthouse News Serv. v. Corsones, 131 F.4th 59 (2d Cir. 2025) (qualified First Amendment right of public access to court documents exists and burden for closure is high)
- United States v. Amodeo, 71 F.3d 1044 (2d Cir. 1995) (framework for weighing common law right of access to judicial documents)
- Nixon v. Warner Commc’ns, 435 U.S. 589 (U.S. 1978) (trial court has discretion over sealing records but must consider public access)