The article gets some factual things wrong and some things right about filing papers "under seal". A litigant may request for a document to be filed under seal. Its a motion. The papers are included with the motion. The court say "OK" and the papers remain under seal or the court says no and the papers are returned to the filer. It seems here that a party filed papers "under seal" without either a) motioning for the court for permission or b) the court never ruled on the motion. Dead people have no privacy rights. And court filings are open to the public...except in cases specified by statute, like raping cases involving minors. I would assume that many of the papers filed in court were obtained by executive branch agencies (police, etc.) these records are also available under NY FOIA laws; NY has an admin. agency that hears denial of access cases...but there they could likely claim a "crime investigation" for many papers but the ones filed in court would likely be deemed outside that exemption.