Willie Banks, et al. v. St. James Parish School Board, et al.

Summary

The United States District Court for the Eastern District of Louisiana addresses Plaintiffs Miyoka Johnson and Rhoda Johnson’s motion to file deposition excerpts under seal based on purported FERPA protections. The court holds that Plaintiffs failed to justify wholesale sealing and that FERPA does not protect records relating to school employees. The motion is granted in part and denied in part, with leave to file redacted versions concealing specified nonparty employee names and initials.

Holdings

1. Plaintiffs did not overcome the presumption of public access because they sought wholesale sealing without conducting the required document-by-document and line-by-line analysis or identifying the specific harm that disclosure would cause.
2. The deposition excerpts concerning school-district employees were not education records protected by FERPA, and FERPA did not provide a basis for sealing the employee information.
3. The court permitted Plaintiffs to refile Exhibits A and C with only the specified nonparty employee names and initials redacted because those identities were irrelevant to the motion and the case generally, and the employees' privacy interest outweighed the public's interest in disclosure of their names.

Questions Presented

1. Whether Plaintiffs established sufficient grounds to file Exhibits A and C entirely under seal despite the presumption of public access to judicial records.
2. Whether FERPA protects personally identifiable information concerning employees of an educational institution in deposition excerpts.
3. Whether the exhibits should instead be publicly filed with redactions limited to irrelevant nonparty employee names and initials.

Disposition

other