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Appellate Division, Third Department · October 22, 2026 · 2026 NY Slip Op 06192

A First Amendment right of access attaches to grievance committee dispositions on a showing of good cause

Matter of Campaign for Accountability (Sarcone-Attorney Grievance Comm. for the Third Jud. Dept.)

Read the official decision: 2026 NY Slip Op 06192

Holding The court held that a presumptive First Amendment right of access attaches to the adjudicatory dispositions of attorney grievance committees, requiring their disclosure upon a showing of good cause. However, the court determined that no such right attaches to investigatory documents or internal work product, which remain confidential unless traditional good cause is established.

Why it matters

Establishes a new constitutional standard for the disclosure of attorney grievance committee dispositions in New York.

Distinguishes between adjudicatory dispositions (subject to First Amendment access) and investigatory records (subject to statutory confidentiality).

The court’s words

we agree that the presumptive First Amendment right of access attaches to AGC's adjudicatory disposition of respondent's disciplinary proceeding

2026 NY Slip Op 06192, at the official text

we conclude that the documents within AGC's control are investigatory in nature, that no presumptive right of access applies

2026 NY Slip Op 06192, at the official text

we grant that part CfA's application which seeks divulgence of the admonition which AGC imposed upon respondent

2026 NY Slip Op 06192, at the official text

we deny CfA's application for divulgence to the extent that CfA has sought respondent's responsive papers

2026 NY Slip Op 06192, at the official text
CourtAppellate Division, Third Department
DecidedOctober 22, 2026
Citation2026 NY Slip Op 06192
Area of lawAttorney Discipline and Professional Responsibility
WeekWeek ending October 24, 2026
Official textOfficial decision: 2026 NY Slip Op 06192
Publication statusSlip opinions are uncorrected and subject to revision before publication in the Official Reports.
Source feedNew York slip opinion page
Law Watch record id1484

Same court and area in the last 180 days

Recommended citation

ESQ HQ, New York Law Watch, Matter of Campaign for Accountability (Sarcone-Attorney Grievance Comm. for the Third Jud. Dept.), 2026 NY Slip Op 06192 (Appellate Division, Third Department, October 22, 2026), https://esqhq.com/decisions/2026-ny-slip-op-06192/

How this record was made

Holding drafted by Law Watch’s in-house model, graded by three reviewers; every quotation verified word for word against the official text.

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Featured by Eric McAvey, November 14, 2026.

Published October 22, 2026. Updated November 14, 2026.