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 defendants’ request to seal administrative-record materials and limited access to attorneys and court personnel.
The order protects the privacy of the minor students and restricts public access to the administrative record; access remains available to attorneys appearing for the parties and court personnel.
What happened
Ambrister v. Banks concerns a case under the Individuals with Disabilities Education Act involving educational services for minor students. The defendants asked to seal exhibits containing information that could identify the students and reveal medical, disability, and education records. The plaintiffs consented to the request.
The court found that the students’ privacy interests outweighed the public’s usual right to access court records. It granted the application to file the administrative record under seal and restricted access to attorneys appearing for the parties and court personnel.
Judge Jessica G. L. Clarke ordered the Clerk of Court to terminate ECF No. 16. The order was entered on July 7, 2025.
The detailed version
- Ambrister v. Banks · No. 1:24-cv-08403
- Clarke
- July 7, 2025
Background
The defendants—the New York City Department of Education and David C. Banks in his official capacity—asked for permission to file certain exhibits to the administrative record under seal. The case involves educational services provided to minor students under the Individuals with Disabilities Education Act.
The defendants stated that publicly filing the exhibits could reveal the identities of the named plaintiffs and disclose personally identifiable information, including medical history, disabilities, educational records, and information about educational progress and history. The defendants cited privacy protections under the Federal Rules of Civil Procedure, the Individuals with Disabilities Education Act, and the Family Educational Rights and Privacy Act. The plaintiffs consented to the request.
Court’s ruling
The court granted the application. Applying the standard from Lugosch v. Pyramid Co. of Onondaga, the court concluded that the defendants showed that the interests in filing the administrative record, ECF No. 17, under seal outweighed the presumption of public access. Access to the sealed material is restricted to attorneys appearing for the parties and court personnel.
The court also directed the Clerk of Court to terminate ECF No. 16. The order was signed by Judge Jessica G. L. Clarke.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.