BUFFALO, NY – A federal judge in the Western District of New York has granted a request by the Town of Lancaster and two local police officers to seal court documents related to the 2022 arrest of plaintiff Michael A. Vanyo.
In a Decision and Order dated January 15, 2026, U.S. District Judge Lawrence J. Vilardo ruled that although filings attached to summary judgment motions are generally subject to a strong presumption of public access, the specific exhibit at issue—Vanyo’s state court criminal file—should remain sealed to comply with New York law and to protect the privacy of a nonparty complainant.
Vanyo filed suit in 2023 against the Town of Lancaster and two officers, Richard Albert and Christopher Keppner, alleging violations stemming from his July 2022 arrest. The defendants removed the case to federal court and later moved for summary judgment. Along with that motion, they sought to file Vanyo’s criminal case records under seal.
Judge Vilardo noted that documents submitted with a summary judgment motion are considered “judicial documents,” meaning the public typically has a constitutional and common-law right to access them. But that right can be overcome by compelling interests such as privacy or statutory confidentiality.
The court found that the records were automatically sealed under New York Criminal Procedure Law § 160.50, which requires sealing when a criminal case ends in a person’s favor. Citing Crosby v. City of New York, the judge emphasized that the statute’s purpose is to protect individuals from the stigma of unproven accusations.
Additionally, the court recognized a legitimate privacy interest in protecting the identity of the complainant who reported the alleged incident leading to Vanyo’s arrest.
Because those interests outweighed the presumption of public access, Judge Vilardo granted the motion to seal, ruling that the closure was “narrowly tailored” and necessary to preserve higher privacy values.
Key Points: Judge seals criminal records in Lancaster arrest civil suit – Western District of New York
- U.S. District Judge Lawrence J. Vilardo granted a motion to seal Vanyo’s state court file, an exhibit in the defendants’ summary judgment motion.
- The records were previously sealed under N.Y. C.P.L. § 160.50 and contained sensitive information about a nonparty complainant.
- The court found these privacy concerns outweighed the strong presumption of public access to judicial documents.
