Yes but again, please don't conflate these two unrelated topics. Bork's video rental records were voluntarily disclosed by a video rental shop to a newspaper reporter. A person has no particular constitutional right to privacy in such matters. This was Bork's own opinion on the matter! Later, Congress passed a law making such records private.

But that's all neither here nor there. We're discussing a court order. No law prevents a court from ordering the disclosure of video rental records, even today with the Video Privacy Protection Act, because the VPPA allows disclosure "to a law enforcement agency pursuant to a warrant issued under the Federal Rules of Criminal Procedure". Because that's what courts do. There's really nothing that is protected from court orders in the US, except for a few well-known, very narrow exemptions.