## Facts

- An adult adoptee, adopted in New York in 1968 at 11 months old, petitioned to unseal his adoption records under Domestic Relations Law (DRL) § 114(2).
- He sought only two certified copies of his original, pre-adoption birth certificate to document Hungarian lineage for a Hungarian citizenship application.
- His adoptive parents were deceased, and he provided their death certificates.
- His biological mother was a Hungarian citizen and submitted an affidavit consenting to the requested disclosure.
- The biological father was unknown.
- The petitioner submitted documentation supporting his citizenship-related need, including the adoption order, his amended birth certificate, his biological mother’s Hungarian records, and evidence of Hungarian citizenship in his maternal line.

## Issues

1. Whether the petitioner demonstrated “good cause” under DRL § 114(2) to unseal sealed adoption records to obtain certified copies of his original pre-adoption birth certificate for Hungarian citizenship purposes.
2. Whether, and to what extent, the court could grant narrowly limited access that protects confidentiality interests while meeting the petitioner’s demonstrated legal need.

## Decision

- The Surrogate’s Court granted the application in part.
- The court ordered the records unsealed only to the extent necessary to issue two certified copies of the petitioner’s original, pre-adoption birth certificate.
- The court did not authorize general access to the full adoption file.

## Legal Principles

- DRL § 114 seals adoption records and permits inspection or disclosure only by court order upon a showing of “good cause.”
- “Good cause” is not statutorily defined and is determined case by case by balancing adoption-confidentiality policies against the petitioner’s demonstrated need.
- Although medical necessity frequently supports good cause, the standard is not limited to medical reasons; substantial, legally cognizable needs may qualify.
- Courts may tailor relief narrowly, permitting limited disclosure sufficient to satisfy the purpose of the application while minimizing intrusion on confidentiality.
- Consent by a biological parent and the absence of meaningful competing privacy interests may reduce the weight of confidentiality concerns in the balancing analysis.

## Conclusion

The court found good cause under DRL § 114(2) where an adult adoptee showed a specific, documented need for certified copies of his original birth certificate to establish Hungarian lineage for citizenship, and it granted only narrowly limited unsealing to issue those certificates.


In re Victor M. I. I., 881 N.Y.S.2d 367 (Sur. Ct. Nassau Cnty. 2009)