Puerto Rico Land & Fruit, S.E. v. Municipality of Culebra, 3:09-cv-02280

PRLF (private partnership) sued Municipality of Culebra and ACDEC in 2009 over alleged civil‑rights violations and illegal seizure of property adjoining Flamenco Lagoon/Flamenco Beach.
PRLF settled with the Municipality and ACDEC on June 6, 2012; the court approved dismissal as to those defendants and the settlement was filed under seal.
The district court retained jurisdiction to enforce the settlement after final dismissal of the case.
Coralations, a Culebra nonprofit focused on coastal protection and public‑beach access, moved to intervene and to unseal the settlement so the public can monitor use and protection of public lands.
The magistrate judge found the settlement is a judicial record that determines substantive rights and applied the common‑law presumption of public access; PRLF, Municipality, and ACDEC did not oppose Coralations’ unsealing motion on the docket.

Issue	Plaintiff's Argument (Coralations)	Defendant's Argument (PRLF/Municipality/ACDEC)	Held
Whether the settlement agreement is a judicial record subject to public‑access analysis	Settlement affects substantive rights involving public land and thus should be accessible	(No response on docket; no articulated confidentiality interest)	Court: Settlement qualifies as a document determining substantive rights; public‑access analysis applies
Whether the settlement should be unsealed under the common‑law presumption (and First Amendment concerns)	Strong public interest: settlement concerns public entities/public land (beach), necessary for public oversight and transparency	No evidence or argument that confidentiality interests outweigh public access; no showing of compelling reasons to seal	Court: Public interest outweighs any unarticulated confidentiality interest; motion to unseal granted. The defendants’ failure to respond waives objection.

Anderson v. Cyovac, Inc., 805 F.2d 1 (1st Cir. 1986) (documents that determine substantive rights are subject to public‑access scrutiny)
Fed. Trade Comm’n v. Standard Fin. Mgmt. Corp., 830 F.2d 404 (1st Cir. 1987) (balancing test for confidentiality vs. public access)
Siedle v. Putnam Inv., Inc., 147 F.3d 7 (1st Cir. 1998) (embarrassment alone insufficient to overcome presumption of access)
Nixon v. Warner Commc’ns, Inc., 435 U.S. 589 (U.S. 1978) (public‑access balancing and the function of monitoring the judiciary)
Dahl v. Bain Capital Partners, LLC, 891 F. Supp. 2d 221 (D. Mass. 2012) (courts may require parties seeking sealing to articulate specific interests; unsealing where parties fail to justify confidentiality)
Erie County v. New York, 763 F.3d 235 (2d Cir. 2014) (heightened public interest where settlement concerns public agencies and public institutions)
Thomas v. Arn, 474 U.S. 140 (U.S. 1985) (procedural consequence: failure to timely object to a magistrate judge’s report waives appellate review)