Lucretia Carter sued Southeastern Oklahoma Family Services, Inc. in the Eastern District of Oklahoma raising claims of sexual harassment, retaliation, negligent supervision, and intentional infliction of emotional distress. The parties filed a joint motion to seal the entire case following settlement.
Factual Overview
Carter initially filed a lawsuit against her former employer in January 2022, raising claims of sexual harassment, retaliation, and negligent supervision. That case was dismissed without prejudice. In November 2023, Carter refiled her case in state court, adding a claim for intentional infliction of emotional distress. The defendant removed the case to federal court. Carter then amended her complaint in January 2024 to add additional facts and a claim of employment discrimination. In August 2024, the parties reached a settlement.
Following settlement, both parties jointly moved to seal the entire case record, arguing that the sensitive nature of the sexual harassment claims, the need to protect confidentiality interests of parties and non-parties, and the desire to avoid having sexual harassment allegations associated with the plaintiff’s name justified sealing the record.
Legal Analysis
Public Access to Court Records: The court began by noting the long-recognized common law right of public access to judicial records. While acknowledging this right is not absolute, the court emphasized that parties seeking to seal records must demonstrate that countervailing interests heavily outweigh the public’s right of access. The court noted that parties must articulate a real and substantial interest justifying the denial of public access.
Evaluation of Parties’ Arguments: The court found the parties’ arguments insufficient to overcome the presumption of public access. While acknowledging the sensitive nature of sexual harassment allegations, the court determined that embarrassing or inflammatory facts alone do not justify sealing court records. The court also rejected the notion that the parties’ mutual agreement to seal could override the public’s right of access to judicial records.
The court denied the parties’ joint motion to seal the action, finding that the desire to protect parties from embarrassment and the sensitive nature of sexual harassment allegations did not outweigh the public’s right of access to court records.
Schrag on Law 