H. v. New York City Department of Education

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

J.H., individually and on behalf of C.H., a child with a disability,

Plaintiff, 26-CV-00854 (JAV) (RFT)

-against- ORDER

NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendant.

ROBYN F. TARNOFSKY, United States Magistrate Judge: On May 27, 2026, Plaintiff filed a letter-motion (ECF 17) to seal the administrative record (“Record”) in this action seeking attorney’s fees in connection with Plaintiff’s claims under the Individuals with Disabilities Education Act, 20 U.S.C. §§ 1400 et seq. (the “IDEA”). Plaintiff requests that the entire Record be sealed because the Record “requires extensive redactions of a minor’s personal information, including the minor’s name, date of birth, and school identification number.” (Id. at 1.) Defendant has consented to this request. (Id.) Plaintiff is correct that families in IDEA cases “have a regularly recognized and established right to privacy concerning . . . the administrative record of an [IDEA] impartial due process hearing.” (Id.) However, I am not persuaded that the entire Record must be sealed to protect the privacy interest of the minor Plaintiff. “Rather than sealing [the Record] in full, it is appropriate for [it] to be publicly filed, with [C.H.’s] sensitive information redacted.” A.S. on behalf of T.B. v. New York City Dep’t of Educ., No. 23-CV-4580 (JPC), 2024 WL 4354894 at 2 n.2 (S.D.N.Y. Sept. 30, 2024) (granting request to seal exhibits containing the plaintiff’s sensitive personal information but denying the request as to other exhibits and requiring those exhibits to be resubmitted pursuant to the judge’s individual rules). Therefore, Plaintiff is directed, by June 18, 2026, to submit appropriate proposed redactions as required by my Individual Rules and Practices.

DATED: May 29, 2026 SO ORDERED. New York, NY mr ROBYN F. TARNOFSKY United States Magistrate Judge