Bird v. Aviles-Ramos
- John Cronan
- 1:25-cv-09494
- U.S. District Court · Southern District of New York
- 3
In Bird v. Aviles-Ramos, Judge Cronan granted the plaintiff’s request to file H.C.’s sensitive special-education record under seal.
H.C., whose sensitive health and educational information appears in the administrative record, and the parties whose litigation record will be filed under seal.
What happened
Bird et al. v. Aviles-Ramos et al. is an Individuals with Disabilities Education Act case involving H.C.’s administrative record. The plaintiff asked to file that record under seal because it contains H.C.’s health, disability, and educational information.
The plaintiff argued that the record’s more than 1,500 pages contained highly sensitive, personally identifying information, and that redacting it would be burdensome and make the record difficult to understand. The defendants agreed to filing the record under seal.
Judge John P. Cronan granted the request, finding that the sensitive information in H.C.’s individualized education program, administrative submissions and decisions, and hearing transcripts justified sealing under the governing public-access standard. The court directed the Clerk of Court to close Docket 18.
The detailed version
- Bird v. Aviles-Ramos · No. 1:25-cv-09494
- John Cronan
- Aug. 19, 2026
Background
The plaintiff brought this action under the Individuals with Disabilities Education Act, a federal law governing special-education services. The plaintiff asked the court for permission to file the certified record from the underlying state administrative proceedings under seal. The record includes H.C.’s individualized education program, submissions made during the administrative proceedings, state administrative decisions, and hearing transcripts.
The plaintiff stated that the record is more than 1,500 pages and contains confidential, personally identifiable information about H.C., including information about her health, disability, and educational services. The plaintiff argued that protecting this information was a compelling privacy interest and that redaction would be overly burdensome and would make the record unintelligible for evaluating the case. The defendants agreed to filing the record under seal.
Court’s ruling
The court granted the plaintiff’s request to file the administrative record under seal. Applying the standard governing public access to judicial documents, the court found that the record’s information about H.C.’s health was extremely sensitive and that sealing satisfied the applicable standard. The Clerk of Court was directed to close Docket 18.
The opinion does not decide the underlying dispute about H.C.’s special-education services or the merits of the action.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.