Larach Cohen v. Aviles-Ramos
- Jesse Furman
- 1:25-cv-01195
- U.S. District Court · Southern District of New York
- 2
In Larach Cohen v. Avilés-Ramos, Judge Furman temporarily granted the plaintiff’s request to seal a sensitive administrative record.
The plaintiff, M.C., and anyone seeking public access to the certified administrative record are affected. The record will remain temporarily sealed while the court later considers whether continued sealing or redaction is appropriate.
What happened
Larach Cohen v. Avilés-Ramos is an action under the Individuals with Disabilities Education Act. The plaintiff asked the court to seal a certified administrative record that would be used in the parties’ planned summary-judgment motions.
The record is more than 1,000 pages and contains personally identifying information about M.C., a minor, including information about health, disabilities, and education. The plaintiff argued that sealing was necessary to protect that information and that extensive redaction would make important documents difficult to understand.
Judge Jesse M. Furman temporarily granted the motion to seal. The court said it would decide later, when considering the underlying motion, whether the materials should remain sealed or be redacted, and directed the clerk to terminate ECF No. 17.
The detailed version
- Larach Cohen v. Aviles-Ramos · No. 1:25-cv-01195
- Jesse Furman
- May 5, 2025
Background
The plaintiff brought this action under the Individuals with Disabilities Education Act, a federal law concerning educational rights of children with disabilities. The plaintiff filed a certified administrative record from IHO Case No. 250887 and requested that the record be kept under seal. The record was expected to be used and cited in the parties’ motions for summary judgment.
Request to Seal
The request stated that the record is more than 1,000 pages and contains confidential, personally identifiable information about M.C., a minor. The information includes details about M.C.’s health, disabilities, educational needs, and the health and educational services involved in the case. The request also stated that the record includes an individualized education plan, which the court would need to review in evaluating whether the education provided met the statutory standard of a free appropriate public education.
The plaintiff argued that the privacy interests protected by the Individuals with Disabilities Education Act supported sealing the record. The plaintiff further argued that redaction would be too burdensome and would make important portions of the record unintelligible or useless for evaluating the case.
Ruling
The motion to seal was granted temporarily. The court will assess, when deciding the underlying motion, whether the materials should remain sealed or instead be sealed in part or redacted. The clerk was directed to terminate ECF No. 17. This order did not decide the underlying dispute or the parties’ summary-judgment motions.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.