Diaz v. Aviles-Ramos
- John Koeltl
- 1:25-cv-01241
- U.S. District Court · Southern District of New York
- 2
In Diaz v. Avilés-Ramos, Judge Koeltl granted plaintiffs’ request to file the administrative record under seal to protect a minor’s privacy.
The plaintiffs, including N.D., a minor whose confidential health and education information appears in the administrative record, and the parties and public seeking access to that record.
What happened
In Diaz v. Avilés-Ramos, the plaintiffs asked to file the administrative record under seal in their case under the Individuals with Disabilities Education Act. The record concerns N.D., a minor, and includes sensitive health and education information.
The plaintiffs argued that sealing was necessary to protect N.D.’s privacy and that redacting the record would be impractical because it exceeds 1,000 pages and contains confidential information throughout. They also argued that extensive redactions would make important materials, including N.D.’s education plan, difficult to understand.
Judge John G. Koeltl granted the application. The opinion states that sealing the record protects a compelling privacy interest while preserving the record’s usefulness in evaluating the case.
The detailed version
- Diaz v. Aviles-Ramos · No. 1:25-cv-01241
- John Koeltl
- June 17, 2025
Background
The plaintiffs, represented by counsel, brought this action under the Individuals with Disabilities Education Act. They asked permission to file the administrative record under seal. The record contains confidential and personally identifiable information about N.D., a minor, including information about N.D.’s health, disabilities, education, and the services needed to provide a free and appropriate public education.
Request to Seal
The plaintiffs relied on the general presumption that judicial documents should be publicly accessible, while arguing that N.D.’s privacy interests justified limiting access. They cited federal provisions requiring confidentiality for personally identifiable information and records concerning children with disabilities and their parents.
The plaintiffs also argued that sealing the entire record was narrowly tailored to protect that privacy interest. The record exceeds 1,000 pages and contains confidential information throughout. According to the application, redacting the information would be overly burdensome and would make important materials, including N.D.’s individualized education program, unintelligible or useless for evaluating whether the education program met N.D.’s health and educational needs.
Ruling
The court granted the application to file the administrative record under seal. The ruling accepted the stated need to protect the minor’s highly sensitive information and the explanation that redaction would prevent the record from remaining useful for evaluating the case. The opinion does not decide the underlying merits of the Individuals with Disabilities Education Act claims.
Disposition
Application granted.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.