Anderson v. Eastern Connecticut Health Network Inc.
Although a strong presumption exists against sealing court documents, a court may grant a motion to seal, if a party makes a particularized showing of good cause. The plaintiff, Harry Anderson, sued the Eastern Connecticut Health Network. The parties jointly requested a protective order, to seal documents in the court file. The District Court observed that the parties' agreement to seal did not constitute a sufficient basis to grant the request for a protective order. A strong presumption against sealing exists, and judicial records may be sealed only when, and to the extent necessary, to preserve "higher values," pursuant to Hartford Courant Co. v. Pellegrino, a 2004 decision of the 2nd Circuit. Anderson made a particularized showing of good cause to depart from the strong presumption against sealing. Anderson indicated that he will sign medical releases, to permit the defendant to obtain his medical records. The court indicated that the courtroom will remain presumptively open to the public. "[N]o closure order will be entered," wrote the court, "except on a specific written request of a party supported by a showing of sufficient cause."