Garzon v. Aviles-Ramos
- John Koeltl
- 1:25-cv-05284
- U.S. District Court · Southern District of New York
- 2
In Garzon v. Aviles-Ramos, Judge Koeltl granted plaintiffs’ request to file the confidential IDEA administrative record under seal.
The plaintiffs, particularly M.G., whose sensitive health and education information appears in the Certified Record, and members of the public seeking access to that record.
What happened
Garzon et al. v. Aviles-Ramos et al. is an action under the Individuals with Disabilities Education Act. The plaintiffs asked to file the administrative record under seal.
The record is more than 600 pages and contains sensitive, personally identifying information about M.G., a minor, including information about her health, disabilities, education, and needed services. The plaintiffs argued that sealing was necessary to protect M.G.’s privacy while allowing the court to review the case record.
Judge John G. Koeltl granted the application to file the Certified Record under seal. The order does not separately describe any additional conditions or redactions.
The detailed version
- Garzon v. Aviles-Ramos · No. 1:25-cv-05284
- John Koeltl
- Nov. 19, 2025
Background
The plaintiffs brought this action under the Individuals with Disabilities Education Act, a federal law concerning education-related rights and procedural protections for children with disabilities. The court must receive the administrative-proceeding records in this type of action.
Request to Seal
The plaintiffs asked for permission to file the Certified Record under seal. The record is more than 600 pages and contains confidential and personally identifying information about M.G., a minor, including details concerning her health, disabilities, education, and the health and educational services she needs. Plaintiffs’ counsel stated that defendants’ counsel had been contacted but had not yet responded.
The application argued that protecting this information was a compelling privacy interest. It also argued that sealing the entire Certified Record was narrowly tailored because the record was extensive, contained confidential information throughout, and the information was important to the court’s evaluation of the case.
Ruling
Judge John G. Koeltl granted the application. The Certified Record may therefore be filed under seal. The text provided does not state any additional sealing conditions or identify separate redactions ordered by the court.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.