Rocco v. New York State Court Officers Association
- Lewis Liman
- 1:23-cv-10973
- U.S. District Court · Southern District of New York
- 1
In Rocco v. New York State Court Officers Association, Judge Liman granted Rocco’s request to seal medical records.
Jerry Rocco, whose medical-record exhibit was ordered sealed, and members of the public seeking access to that information.
What happened
In Rocco v. New York State Court Officers Association, Jerry Rocco asked to file an exhibit under seal while opposing the Association’s motion for summary judgment. The exhibit contained his medical records.
The court said court documents generally should be publicly accessible when they are used to decide legal rights. But it found that the privacy interests in Rocco’s personal medical information outweighed the public’s right to see it in this case.
Judge Lewis J. Liman granted the request to seal the exhibit and directed the Clerk of Court to close Dkt. No. 48.
The detailed version
- Rocco v. New York State Court Officers Association · No. 1:23-cv-10973
- Lewis Liman
- June 5, 2025
Background
Jerry Rocco requested permission to file an exhibit under seal in connection with his opposition to the New York State Court Officers Association’s motion for summary judgment. The exhibit consisted of medical records describing Rocco’s condition and treatment.
Court’s Reasoning
The court recognized a strong presumption that the public may access documents used to decide litigants’ substantive legal rights. It also explained that personal medical information can create significant privacy interests that outweigh that presumption when protection is narrowly tailored. The court found that Rocco’s privacy interest in his medical records outweighed the public’s right of access in this instance.
Ruling
Judge Lewis J. Liman granted Rocco’s request to file the exhibit under seal. The court directed the Clerk of Court to close Dkt. No. 48. The opinion does not state that the court ruled on the underlying motion for summary judgment.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.