In Re ADOPTION OF SCOTT W.V., 124 A.3d 1181

Scott W.V., born 1958, sought access to his sealed adoption file to learn about his birth father; initial non-identifying summary was provided in 2002.
In 2012 the circuit court appointed an intermediary and a private investigator under FL § 5-3A-41 to locate the birth father and obtain medical information; their year-long, exhaustive search failed to identify or locate him.
The court and guardians ad litem reviewed and redacted intermediary and investigator reports; appellant received redacted versions but later sought a "fresh review" and release of additional redactions that he asserted pertained only to the birth father.
Appellant argued that because professionals could not identify the father from the redacted material, the redactions must be non-identifying and therefore releasable under FL § 5-3A-40 (non-identifying info available without showing of need).
The circuit court denied appellant’s motion in a single sentence, concluding there was no further non-identifying information to release; appellant appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Proper interpretation of "identifying information" under FL § 5-3A-01(d)	The redacted items did not reveal identity or location; because an exhaustive professional search failed to ID the father, those items are non-identifying and must be released under FL § 5-3A-40 without a need showing	The court treated the redactions as identifying; a broader protection of information that could lead to discovery is appropriate to protect privacy interests	Court construed "reveals" to mean information that "could reasonably lead to the discovery of" identity/location (broader than plaintiff urged), but remanded because the trial court gave no itemized analysis explaining why each requested redaction remained identifying.
2. Whether trial court abused discretion / failed to issue required written findings (Md. Rule 16-1009)	Court erred by not making written, item-by-item findings and balancing special/compelling reasons to disclose against privacy interests	Trial court issued a single-sentence denial; respondent relies on preservation rules and court discretion	Appellate court held the Rule 16-1009 argument was not preserved below, so it did not decide the merits; nonetheless remanded for the trial court to make specific findings on each redaction so appellate review is possible.

Lockshin v. Semsker, 412 Md. 257 (discusses rules and principles of statutory construction)
Sumpter v. Sumpter, 427 Md. 668 (remand required where record lacks trial court findings on sealing/inspection; discusses Md. Rule 16-1009)
Schisler v. State, 394 Md. 519 (standard that appellate review determines legal correctness of trial court application of statute)
Baltimore Sun Co. v. Colbert, 323 Md. 290 (courts must articulate interest sought to be protected when sealing records)