Ambrister v. Banks
- Clarke
- 1:24-cv-08403
- U.S. District Court · Southern District of New York
- 2
In Ambrister v. Banks, Judge Clarke granted plaintiffs’ request to seal a sensitive administrative record involving minor R.D.
The plaintiffs, particularly minor R.D., whose health and education information is contained in the administrative record; access is limited to the parties’ attorneys and court personnel.
What happened
In Ambrister v. Banks, the plaintiffs asked to file the administrative record under seal. They said it contained private information about R.D., a minor, including details about her health, disabilities, and education.
The plaintiffs argued that sealing was necessary to protect R.D.’s privacy and that redacting the record would be impractical because it was more than 2,000 pages and contained extensive confidential information. They also said the record needed to remain understandable so the court could evaluate the case.
Judge Jessica G. L. Clarke granted the application. The court found that the privacy interests supporting secrecy outweighed the public’s usual right to access court documents. Access to the sealed record is limited to the parties’ attorneys and court personnel, and the clerk was directed to terminate ECF No. 22.
The detailed version
- Ambrister v. Banks · No. 1:24-cv-08403
- Clarke
- July 7, 2025
Background
Plaintiffs asked the court for permission to file the certified administrative record under seal. The record concerns R.D., a minor, and contains personally identifiable information and sensitive details about her health, disabilities, education, and the health and educational services relevant to her education. The submission stated that the record was more than 2,000 pages long.
Sealing request
Plaintiffs argued that the minor’s privacy interests outweighed the common-law presumption that judicial documents should be publicly accessible. They also argued that sealing the entire record was narrowly tailored because redaction would be excessively burdensome and would remove information needed to understand the record, including R.D.’s individualized education plan. Plaintiffs relied on privacy protections associated with the Individuals with Disabilities Education Act and cited decisions permitting sealed filings in similar actions involving minors.
Ruling
The court granted the application. Applying the balancing approach described in Lugosch v. Pyramid Co. of Onondaga, the court concluded that plaintiffs had shown that the interests supporting filing the administrative record under seal outweighed the presumption of public access. The court restricted access to attorneys appearing for the parties and court personnel. The clerk was directed to terminate ECF No. 22. This order addressed access to the record and did not decide the underlying merits of the action.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.