Matter of Chattman, 65 N.Y.2d 786 (1985)

When an adopted person seeks access to confidential adoption information for good cause, the court must balance the interests of the adopted person, adoptive parents, biological parents, and society, requiring notice to the biological parents (if possible) or appointment of a guardian and a hearing.

Summary

An adopted adult sought access to sealed adoption records to obtain medical history that could aid in treating a heart condition and allow recertification as a commercial pilot. The New York Court of Appeals held that granting access to adoption records requires a careful balancing of the competing interests of the adopted person, adoptive parents, biological parents, and society. The court emphasized the importance of maintaining the confidentiality of adoption records to protect the privacy of biological parents and the integrity of the adoption process. The court mandated notice to biological parents (if feasible) or appointment of a guardian ad litem and a hearing to properly assess these competing interests before any disclosure is ordered. Summary judgment was therefore inappropriate.

Facts

Plaintiff was adopted in 1932. In 1983, the adoption agency provided him with some medical and historical information about his biological parents, but withheld the biological father’s name, hometown, and college. The plaintiff, suffering from a heart condition, sought further information, claiming genetic information was vital for treatment and for recertification as a commercial pilot. His adoptive parents were deceased.

Procedural History

The plaintiff filed a motion seeking permission to examine adoption records. The initial motion was delayed while the defendant attempted to locate the biological mother. After the defendant was unable to locate either parent, the plaintiff filed a second motion, which was dismissed for administrative reasons. The plaintiff then renewed the original motion. Special Term granted the motion, finding good cause for disclosure, and the Appellate Division affirmed. The New York Court of Appeals granted leave to appeal and stayed the proceedings.

Issue(s)

Whether an adopted person seeking access to confidential adoption records must provide notice to the biological parents (if possible) or a guardian appointed to represent their interests, and have a hearing, where necessary, before a finding of good cause may be made and the adopted person granted the relief requested.

Holding

Yes, because granting access to adoption records requires a careful balancing of the competing interests of the adopted person, adoptive parents, biological parents, and society, and this balancing cannot occur without notice to all necessary parties and, in most cases, a hearing.

Court’s Reasoning

The Court reasoned that access to confidential adoption information could harm the interests of adoptive parents, biological parents, and society. Adoptive parents need to be shielded from interference by biological parents. Biological parents must be assured their privacy will not be disturbed. Society has an interest in providing substitute families through adoption, which could be damaged by disclosure. The Court stated: “The success of the adoptive process in New York clearly depends upon the privacy of that process for those men and women who are confronted with the circumstance of an unwanted pregnancy or inability to provide the necessary care for their children.” The court emphasized that a “court proceeding would be meaningless, however, if both sets of parents were given no opportunity to articulate their interests in maintaining their anonymity.” The Court acknowledged the medical needs of adopted children but cautioned against automatically granting full disclosure. It suggested correspondence through a guardian ad litem as a possible solution. The court noted that the Legislature had addressed the competing interests by allowing agencies to release medical information with identifying information redacted (Social Services Law § 373-a). The dissenting opinion is not mentioned.