In Re: The Roman Catholic Diocese of Rockville Centre, New York

Background

The Roman Catholic Diocese of Rockville Centre, New York filed a chapter 11 bankruptcy case in 2020. Ten anonymized appellants filed confidential sexual-abuse proofs of claim against the Diocese in that bankruptcy case. The bankruptcy court later disallowed those claims after sustaining the Diocese’s objection that the claims did not properly allege a basis for imposing liability on the Diocese. The appellants appealed that ruling to the district court.

The proofs of claim were included in the appellate record, but the appellants did not submit them under seal in the district court. The Diocese filed a motion, on consent, asking permission to submit the proofs of claim under seal. The appellants agreed through their counsel.

Sealing request

The Diocese argued that the proofs of claim should remain confidential under the bankruptcy court’s confidentiality procedures. It stated that the documents contain identifying information, allegations concerning sexual abuse, information about the alleged physical and psychological effects of the abuse, details about the circumstances of the alleged abuse, educational, employment, and marital history, and the names of healthcare providers.

The motion discussed the three-step analysis used for documents filed in court: whether the documents are judicial documents, the strength of the public-access presumption, and whether competing interests outweigh that presumption. The Diocese argued that the claim documents are judicial documents because they bear on the district court’s consideration of the appeal, but that the appellants’ privacy interests justify sealing them. The motion also relied on the confidentiality protocol established in the bankruptcy case and New York’s statutory protection for the identities of sexual-assault victims.

Ruling

Judge Alvin K. Hellerstein granted the motion to seal. The ruling required that full copies be provided to the court for maintenance in its chambers files. It also required the parties to review each sealed document and file public redated copies of the documents filed under seal. The order addressed only the handling of the confidential proofs of claim; the provided text does not state a ruling on the underlying appeal from the bankruptcy court’s disallowance of the claims.