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
| Court | Appellate Division, Third Department |
|---|---|
| Decided | October 22, 2026 |
| Citation | 2026 NY Slip Op 06192 |
| Area of law | Attorney Discipline and Professional Responsibility |
| Week | Week ending October 24, 2026 |
| Official text | Official decision: 2026 NY Slip Op 06192 |
| Publication status | Slip opinions are uncorrected and subject to revision before publication in the Official Reports. |
| Source feed | New York slip opinion page |
| Law Watch record id | 1484 |
Same court and area in the last 180 days
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The court found the respondent attorney guilty of multiple violations of the Rules of Professional Conduct based on stipulated facts regarding neglect and failure to communicate. The court imposed a censure and required the attorney to submit semiannual lists of active cases to the court until further order.
- Matter of Attorneys in Violation of Judiciary Law § 468-a. (Balden)2026 NY Slip Op 05839
The court granted the respondent’s motion for reinstatement to the practice of law, finding by clear and convincing evidence that he met the requisite character and fitness standards. However, the reinstatement is subject to the condition that the respondent file an amended biennial registration statement and provide proof of compliance within 60 days.
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The court granted the respondent’s motion for reinstatement after determining by clear and convincing evidence that the respondent complied with the suspension order and possesses the requisite character and fitness to practice law. The court further found that reinstatement would be in the public interest, thereby reinstating the respondent as an attorney and counselor-at-law effective immediately.
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.
Read how Law Watch worksFeatured by Eric McAvey, November 14, 2026.