Litigants and their lawyers often seek to retroactively seal or pseudonymize cases. Courts sometimes allow this, but often reject it. In particular, that a case has settled is generally not seen as a basis for retroactively sealing it, even when the case settles shortly after filing without any substantive decision from the court; see, e.g., Bernstein v. Bernstein Litowitz Berger & Grossmann (2d Cir. 2016):
The fact that a suit is ultimately settled without a judgment on the merits does not impair the "judicial record" status of pleadings. It is true that settlement of a case precludes the judicial determination of the pleadings' veracity and legal sufficiency. But attorneys and others submitting pleadings are under an obligation to ensure, when submitting pleadings, that "the factual contentions [made] have evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery."
In any event, the fact of filing a complaint, whatever its veracity, is a significant matter of record. Even in the settlement context, the inspection of pleadings allows "the public [to] discern the prevalence of certain types of cases, the nature of the parties to particular kinds of actions, information about the settlement rates in different areas of law, and the types of materials that are likely to be sealed." Thus, pleadings are considered judicial records "even when the case is pending before judgment or resolved by settlement."
And courts are especially reluctant to retroactively seal or even retroactively redact documents that had been available in the open record for months or year, see Gambale v. Deutsche Bank AG (2d Cir. 2004):
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