Matter of Jane Tyler

Summary

The Delaware Supreme Court affirmed the Court of Chancery’s orders maintaining under seal a Guardianship Monitoring Program report concerning alleged sexual abuse of a person with a disability. The Court held that Court of Chancery Rule 180-D provided an adequate basis for confidentiality and that the appellants’ asserted due process interests did not outweigh the State’s interest in protecting abuse-investigation information. The Court did not decide whether 24 Del. C. § 1768 independently supported sealing.

Holdings

1. Court of Chancery Rule 180-D provided an adequate basis to keep the Guardianship Monitoring Program report under seal because access by the appellants could be harmful or detrimental to the disabled person.
2. Assuming the appellants had a cognizable due process interest in addressing reputational harm, their due process interests did not require release of the Guardianship Monitoring Program report.
3. The Vice Chancellor did not improperly summarily overrule the appellants' exceptions; the record reflected a de novo review of the Master's report and supplement.

Questions Presented

1. Whether Court of Chancery Rule 180-D authorized continued sealing of the Guardianship Monitoring Program report upon a showing that access by specific interested parties would be harmful or detrimental to Jane.
2. Whether maintaining the Guardianship Monitoring Program report under seal violated the appellants' due process rights.
3. Whether the Vice Chancellor improperly overruled the appellants' exceptions without meaningful review or a sufficient explanation.

Disposition

affirmed