S.D. v. Genalo
- Vernon Broderick
- 1:22-cv-03063
- U.S. District Court · Southern District of New York
- 3
In S.D. v. Genalo, Judge Moses granted S.D.’s request to seal two sensitive exhibits.
S.D.’s two exhibits will be shielded from public view, while access to the rest of the case remains governed by the court’s orders.
What happened
In S.D. v. Genalo, S.D. asked to file two exhibits to an amended petition under seal: a social worker’s letter and a medical-record review. The materials contained personal, medical, and mental-health information.
The court found that the sensitive information outweighed the public’s right to view the materials and that sealing two exhibits was narrowly limited. The court allowed S.D. to file the exhibits under seal and directed the clerk to seal the same exhibits filed with the original petition.
Judge Barbara Moses issued the order on May 5, 2022. The order addressed only sealing and did not decide the underlying petition.
The detailed version
- S.D. v. Genalo · No. 1:22-cv-03063
- Vernon Broderick
- May 5, 2022
Background
S.D. filed a petition for a writ of habeas corpus and planned to file an amended petition. S.D. asked for permission to file two exhibits under seal: Exhibit D, a letter from social worker Enmanuel Garcia, and Exhibit E, a medical-record review by Dr. Ucik. The exhibits contained information about S.D.’s housing after release, outpatient psychiatric care, mental-health diagnoses, treatment recommendations, medical records, assessments, test results, diagnoses, and hospital visits.
The court had previously denied S.D.’s request to proceed anonymously using initials, while allowing a later request for narrower sealing or redaction. S.D. therefore planned to refile the petition using S.D.’s full name and sought to protect only the two exhibits. The request was not opposed by counsel for the respondents.
Court’s reasoning
The court applied the public-access presumption, which generally favors public access to court records, and considered whether competing interests outweighed that presumption. It also required the sealing request to be narrowly tailored to the reason for restricting access.
The court concluded that the highly sensitive personal, medical, and mental-health information in the two exhibits outweighed the presumption of public access. It also concluded that sealing two exhibits was narrowly tailored. The order states that the application was granted for substantially the reasons in S.D.’s letter.
Disposition
The court granted S.D.’s application to file Exhibits D and E to the amended petition under seal. It also directed the clerk to place Exhibits D and E from the original petition—Docket Nos. 1-4 and 1-5—under seal at the applicable-parties viewing level. This order did not resolve the underlying habeas petition.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.