Ambrister v. New York City Department of Education

Background The action was brought under the Individuals with Disabilities Education Act on behalf of minor student R.D. The New York City Department of Education asked for permission to file the certified administrative record, identified as ECF No. 35, under seal.

Request to Seal The Department represented that the record contained confidential information, including R.D.'s name, date of birth, other identifying information, medical history, disabilities, educational progress, and educational history. The record also included transcripts from hearings before the Impartial Hearing Office and State Review Office, along with exhibits and educational records.

The Department argued that the information was protected under the Federal Rules of Civil Procedure, the Individuals with Disabilities Education Act, and the Family Educational Rights and Privacy Act. It also argued that the underlying administrative proceeding was presumptively closed to the public and that protecting R.D.'s privacy interests outweighed the public's interest in access. Plaintiffs' counsel consented to the request.

Ruling The court granted the request to file the administrative record under seal. Judge Analisa Torres concluded that the Department met its burden to show that the interests supporting sealing outweighed the presumption of public access under the standard from Lugosch v. Pyramid Co. of Onondaga. The order addressed the record's filing status and did not decide the underlying Individuals with Disabilities Education Act dispute.