Harris v. NYC Human Resources Administration
- John Cronan
- 1:20-cv-02011
- U.S. District Court · Southern District of New York
- 2
In Harris v. City of New York, Judge Cronan granted Mary L. Harris’s request to file a letter under seal because it contained private health information.
Mary L. Harris and the public’s access to the health information contained in the letter; the Clerk of Court was directed to close Docket Numbers 223 and 217.
What happened
In Harris v. City of New York, Mary L. Harris asked to file under seal a letter about her availability for a court conference. The letter contained information about her health.
The request relied on a protective order and court rules governing confidential filings. The court found that Harris’s privacy interest in the health information outweighed the public’s interest in accessing the letter.
Judge John P. Cronan granted the request. He also directed the Clerk of Court to close Docket Numbers 223 and 217; the order states that Docket Number 217 had already been resolved by an earlier order.
The detailed version
- Harris v. NYC Human Resources Administration · No. 1:20-cv-02011
- John Cronan
- May 14, 2025
Background
Mary L. Harris, through her attorneys, requested permission to file under seal a May 12, 2025 letter concerning her availability to appear for a court conference. The request cited Federal Rule of Civil Procedure 5.2(d) and provisions of a protective order in the case.
The request stated that the letter contained Harris’s health information, including information that could require confidential treatment to protect privacy, medical history, or disability-related information. The protective order allowed certain materials to be designated as highly confidential and required a party to ask the court for permission before filing papers containing that material in redacted form or entirely under seal.
Court’s Analysis
The court applied the principle that court documents generally carry a public right of access, but that this interest may be outweighed by legitimate privacy concerns. The court found that Harris’s privacy interest in the health information contained in the letter outweighed the public’s interest in access.
Ruling
The court granted the request to file the letter under seal. Judge John P. Cronan also directed the Clerk of Court to close Docket Number 223. He separately directed the Clerk to close Docket Number 217, stating that Docket Number 217 had been resolved by the order entered at Docket Number 219.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.