P.M. v. Joyce
- Valerie Caproni
- 1:22-cv-06321
- U.S. District Court · Southern District of New York
- 2
In P.M. v. Joyce, Judge Caproni granted P.M.’s application to file a psychological evaluation under seal.
P.M., whose psychological evaluation may be filed under seal and kept from public view; the public’s access to that exhibit is limited.
What happened
P.M. v. Joyce involved P.M.’s pending petition asking for a court order concerning his detention. P.M.’s lawyers asked to submit one additional exhibit under seal.
The exhibit was a twelve-page psychological evaluation containing sensitive medical and personal information, including mental-health diagnoses and treatment recommendations. The application also said the evaluation discussed information related to P.M.’s asylum claim and that Respondents’ lawyer consented to sealing.
Judge Valerie Caproni granted the application. The order therefore allowed the exhibit to be filed under seal and shielded from public view.
The detailed version
- P.M. v. Joyce · No. 1:22-cv-06321
- Valerie Caproni
- July 29, 2022
Background
P.M. had a pending petition for a writ of habeas corpus, a request for a court order addressing allegedly unlawful detention. P.M.’s attorneys submitted an application asking for permission to file one additional exhibit under seal. The exhibit was identified as a psychological evaluation prepared by Diana Franco, a licensed clinical social worker. The application stated that counsel for Respondents consented to sealing.
Application to Seal
The application stated that the twelve-page evaluation contained highly sensitive personal and medical information, including mental-health diagnoses and treatment recommendations. It also contained a narrative about information related to P.M.’s asylum claim. P.M.’s attorneys argued that the privacy and safety concerns associated with this information outweighed the public’s usual right to inspect court records and that filing the exhibit under seal was narrowly tailored to protect that information.
Ruling
The court’s order states: “Application GRANTED.” Judge Valerie Caproni therefore allowed P.M. to file the psychological evaluation under seal. The opinion text does not provide separate reasoning beyond the application’s arguments and does not state any ruling on the underlying habeas petition.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.