If that is so , I stand corrected, however it doesn't alter the situation one bit. Only 0bama can release them unless the court compels him to.
In a crimnal case, can the court trying a case subpoena such a document and get it? ... I think they can, and the potential for lawsuits and crimnal cases challenging Obama's eligibility to even be president based on Constitutional requirements would then be a massive disaster for the legal system and the courts, not to mention a devastating embarrassment for the SCOTUS that they kicked this disaster waiting to happen on down the road!