Judge John M. Hunt

Dennis sought disclosure of his adoption records under Domestic Relations Law §114 on “medical grounds.” He claimed he had a mental illness and no family, stating he saw a psychiatrist and a therapist, and attached a letter from his psychiatrist. The doctor stated Dennis was an outpatient diagnosed with “major depressive disorder, recurrent, with psychotic features.” The court noted §114 placed great emphasis on the confidential nature of adoption records, noting they should be sealed and secret, and prohibiting anyone from disclosing a child’s original surname to the adoptive parents. It noted §114 allowed access to the records only with good cause shown and by court order, stating the rule permitting access for medical treatment reasons was contrary to the general rule calling for confidentiality. The court stated the exception was to be strictly construed as a rule automatically giving full disclosure to any adopted person with medical problems would “swallow New York’s strong policy against disclosure” as soon as that person approached middle age. It denied Dennis’ application, ruling nothing in the doctor’s letter stated that unsealing was required to address any serious physical or mental illness.