Redmond v. Promotico
Law enforcement officers can request that courts protect them by sealing information pertaining to their private homes. The plaintiff, Ronald Redmond, sued the defendant state police officer, James Promotico, alleging that Promotico issued false statements to a newspaper reporter. Promotico requested that the court protect the confidentiality of his home address, which was included in the plaintiff's complaint and the marshal's return of service. Generally, "the judicial authority shall not order that any . . . documents . . . on file with the court or filed in connection with a court proceeding be sealed or their disclosure limited," pursuant to Practice Book §11-20A(b). On the other hand, a court can order that documents be sealed, if the court finds that an "order is necessary to preserve an interest which is determined to override the public's interest in viewing such materials," pursuant to Practice Book §11-20A(c). The defendant state police officer argued that when the legislature enacted Connecticut General Statutes §1-217, which exempts state police officers' home addresses from Freedom of Information Act requests, the legislature recognized that this information should be protected. Apparently, the legislature enacted C.G.S. §1-217 in response to a prison convict's request for the names of every officer of the Department of Correction. Recently, the legislature enacted C.G.S. §18-101f, to expand C.G.S. §1-217 and to protect the personnel, medical and other information of the Department of Correction's employees. Senator John Kissel remarked that some inmates used the Freedom of Information Act to intimidate and harass corrections officers. "[B]ecause our legislature has recognized that the residential addresses of law enforcement officers should remain confidential, and because the defendant, as a law enforcement officer, has a security interest in achieving the same confidentiality," wrote the court, "the defendant's motion to seal is granted."