In Re G.D.L, 223 A.3d 100

G.D.L., born and adopted in D.C. in the mid-1960s, reconnected with his biological mother in 2000 and learned his biological father's identity; the father later indicated he did not want contact.
In 2016 G.D.L. petitioned for copies of his original birth certificate (Department of Health), Superior Court adoption records, and records held by the child-placement agency.
The trial court ordered the child-placement agency to provide redacted copies omitting the biological father’s identifying information; the court did not explicitly order the Department of Health or Superior Court to produce records.
The agency produced approximately 80 pages of redacted documents, including a redacted birth certificate and some court records; G.D.L. appealed the trial court’s refusal to release unredacted Superior Court records and an unredacted original birth certificate.
The D.C. Court of Appeals vacated the partial denial and remanded for further proceedings, clarifying the scope and standard for disclosure of sealed adoption records and sealed birth certificates.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether “child” in D.C. Code § 16-311 includes adult adoptees	G.D.L.: §16-311 should not bar adult adoptees from access; adults seeking their records should be treated differently	Respondents: “child” means minors; protections not required for adults	Court: “child” covers adoptees of any age; adult adoptees are protected by §16-311
Standard and balancing for disclosure under §16-311	G.D.L./CLC: Court should consider only adoptee’s welfare and grant if in adoptee’s interests	Respondents: Court may weigh interests of other affected persons (e.g., biological parents)	Court: Threshold finding required that disclosure would promote/protect adoptee’s welfare; after that the court may in its discretion disclose in whole or part and must balance interests of all affected persons (adoptee’s welfare is paramount)
Whether Dept. of Health must release an unredacted sealed original birth certificate	G.D.L.: He has an absolute/right to copy (or at least a liberal standard) under prior Vital Records law	Respondents: Sealed birth certificates may be released only by court order or under statutory, limited exceptions	Court: No absolute right; trial court should apply the same §16-311 standards (welfare threshold and balancing) when deciding release from Health Department; remand for consideration

In re D.E.D., 672 A.2d 582 (D.C. 1996) (adult adoptee access to adoption records; consent of affected parties is significant)
In re D.B., 133 A.3d 561 (D.C. 2016) (discusses scope of statutory provisions governing adoption records)
In re M.M.D., 662 A.2d 837 (D.C. 1995) (establishes best-interests principle as paramount in adoption statutes)
In re S.E.D., 324 A.2d 200 (D.C. 1974) (recognizes trial court discretion over disclosure of adoption records)
In re C.A.B., 384 A.2d 679 (D.C. 1978) (instructs courts to consider interests of affected third parties when deciding disclosure)
Facebook, Inc. v. Wint, 199 A.3d 625 (D.C. 2019) (standard of statutory interpretation and de novo review)