Layne v. The State of New York Department of Correctional and Community Services
- Philip Halpern
- 7:19-cv-04531
- U.S. District Court · Southern District of New York
- 2
In Layne v. NYDOCCS, Judge Halpern granted Layne’s request to seal unredacted medical records in Exhibits 8 and 9.
Layne’s unredacted medical and psychological records in Exhibits 8 and 9 will remain under seal, limiting public access to those exhibits.
What happened
In Layne v. The State of New York Department of Correctional and Community Services, Layne asked the court to seal medical records submitted with his opposition to defendants’ motions in limine. The records were identified as Exhibits 8 and 9 to the declaration of Eli Balsam.
Layne argued that the exhibits contained highly private medical and psychological information. He also argued that those privacy interests outweighed the public’s general right to access court filings, particularly because the case involved allegations of sexual assault.
Judge Philip M. Halpern granted the request. The court approved sealing the unredacted versions of Exhibits 8 and 9 and directed the clerk to terminate the pending motion.
The detailed version
- Layne v. The State of New York Department of Correctional and Community Services · No. 7:19-cv-04531
- Philip Halpern
- Mar. 21, 2023
Background
Layne filed a letter motion seeking permission to redact and file under seal certain exhibits attached to his opposition to defendants’ motions in limine. He identified Exhibits 8 and 9 to the declaration of Eli Balsam as medical records containing private medical and psychological details.
Sealing request
Layne relied on the general presumption that the public may access judicial documents, together with the court’s authority to balance that presumption against privacy interests. He argued that the records’ confidential and personal nature justified sealing them. The motion also stated that the privacy interests were especially significant because the case involved allegations of sexual assault.
Ruling
Judge Philip M. Halpern granted the request. The order approved sealing the unredacted versions of Exhibits 8 and 9 of the Balsam Declaration, identified as docket entries 164-2 and 164-3. The clerk was directed to terminate the motion pending at docket entry 162. The order addressed access to these exhibits and did not decide the underlying claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.