Jane Doe v. The Trustees of Columbia University

Background

Jane Doe, representing herself, brought claims against the Trustees of Columbia University in the City of New York and Y.K. She asserted a Title IX claim against Columbia based on alleged deliberate indifference to the privacy of Doe and another student, and a state-law defamation claim against Y.K. The claims arose from Columbia’s handling of Doe’s report that she had been sexually assaulted by another former student and from related communications about the university’s Title IX proceedings.

Columbia moved to seal Doe’s complaint and to replace the names of Y.K. and four former students—M.L., J.L., S.J., and K.W.—with pseudonyms and redactions. The court granted that motion on February 21, 2025. Doe then moved for reconsideration, asking the court to identify the five individuals publicly.

Legal Standard

The court explained that reconsideration is an extraordinary remedy. It is generally available only when the moving party identifies an intervening change in controlling law, new evidence, or a clear error or manifest injustice. It is not a way to repeat arguments already presented or obtain a second opportunity to litigate an issue.

The court also explained that federal cases ordinarily use the parties’ real names, but courts may allow anonymity in extraordinary circumstances involving serious privacy concerns. Courts balance the interest in anonymity against the public interest in disclosure and any prejudice to the opposing party. The court considered factors addressing the sensitivity of the litigation, potential retaliation or other harm, vulnerability, privacy, public access, and alternative protections.

Arguments and Analysis

Doe argued that Y.K.’s alleged defamation was not itself highly sensitive, that M.L., J.L., and S.J. were witnesses who did not participate in the underlying Title IX proceedings, and that K.W.’s suicide had already been publicly discussed. She also argued that Columbia had not shown a sufficient factual basis for concealing the identities and had not identified a precedent using a pseudonym for a defendant in a defamation case.

The court denied reconsideration as to Y.K. It concluded that the alleged defamatory conduct was closely connected to the sensitive Title IX proceedings in which Y.K. had participated as a witness. The court treated Y.K. as a third party covered by Title IX’s privacy protections for participants in gender-based misconduct proceedings. It also found that pseudonymization could protect Y.K. and Doe from public scrutiny, retaliation, ridicule, reputational harm, and other consequences, while not preventing Doe from identifying or litigating against him.

The court also maintained the pseudonyms for M.L., J.L., and S.J. It noted that Doe alleged that each had a negative sexual experience on campus involving a person whom Doe alleged had sexually assaulted her. Although the complaint did not allege that these three students were sexually assaulted, the court found that the sensitive allegations and possibility that they could be victims of sexual assault supported protecting their identities. The court further found that keeping them anonymous would not prejudice Doe’s ability to litigate.

The court maintained K.W.’s pseudonym despite recognizing that his death might reduce his own privacy interest. The court reasoned that the complaint connected his suicide to the surrounding Title IX allegations and that protecting his identity could also protect his peers, associates, and loved ones from privacy violations, retaliation, ridicule, and reputational harm. The court stated that the complaint did not disclose K.W.’s medical records or protected health information, but concluded that continued pseudonymization was appropriate as a precaution.

Disposition

Judge Edgardo Ramos denied Doe’s motion for reconsideration. The court therefore maintained the prior order sealing the complaint and requiring pseudonyms and redactions for Y.K., M.L., J.L., S.J., and K.W. The court directed the clerk to terminate the motion, identified as Documents 17 and 21.