Benloss v. FEDERAL DEPOSIT INSURANCE CORPORATION
- Sarah Netburn
- 1:25-cv-09105
- U.S. District Court · Southern District of New York
- 2
In Jayson Benloss v. Federal Deposit Insurance Corporation, Judge Netburn allowed Benloss to file a pseudonym motion but warned his employment concerns likely would not justify it.
Jayson Benloss, who may file a motion seeking to proceed under a pseudonym but was warned that the employment concerns he described may not be enough to obtain anonymity; the Federal Deposit Insurance Corporation and the other defendants, whose interests and the public’s access rights are part of the court’s analysis.
What happened
Jayson Benloss, a former Federal Deposit Insurance Corporation employee, sued under Title VII, the federal workplace-discrimination law, alleging that the agency fired him in retaliation for complaining about racial discrimination. He asked to file a motion seeking permission to proceed under a pseudonym.
Benloss said that publicly connecting his name to the lawsuit could hurt his chances of finding another job. The court explained that federal court filings are generally public and that using a pseudonym is allowed only in narrow circumstances when the need for anonymity outweighs the public’s access rights and any harm to the defendants.
Judge Netburn granted Benloss permission to file the pseudonym motion, but did not grant anonymity itself. Judge Netburn warned that the employment concerns described so far likely would not justify proceeding under a pseudonym, while allowing Benloss to provide additional legal authority and facts.
The detailed version
- Benloss v. FEDERAL DEPOSIT INSURANCE CORPORATION · No. 1:25-cv-09105
- Sarah Netburn
- Dec. 4, 2025
Background
Jayson Benloss, a former employee of the Federal Deposit Insurance Corporation, brought a lawsuit under Title VII of the Civil Rights Act of 1964. He alleges that the Federal Deposit Insurance Corporation terminated his employment in retaliation for complaints about racial discrimination.
Benloss sought permission to file a motion asking to proceed under a pseudonym. He argued that publicly associating his name with the lawsuit could harm his employment prospects while he searched for a new job.
Legal standard
Federal Rule of Civil Procedure 10(a) generally requires a complaint to name all parties. The court explained that pseudonyms also conflict with the public’s common-law right to access court proceedings, a right supported by the First Amendment. Courts in the Second Circuit recognize only narrow exceptions when a plaintiff’s interest in anonymity outweighs the public’s access rights and any prejudice to the defendant.
The court identified relevant considerations, including whether the case involves highly sensitive personal matters, whether disclosure creates a risk of physical, mental, or other harm, whether the plaintiff’s identity has remained confidential, and whether the public interest is served by requiring disclosure.
Ruling
Judge Sarah Netburn granted Benloss leave to file the motion seeking permission to proceed under a pseudonym. The court did not decide that motion or grant Benloss permission to remain anonymous.
The court warned that, based on the limited explanation then provided, the possibility of harm to future employment prospects would likely not justify anonymity. The court noted that employment-discrimination cases are routinely litigated under plaintiffs’ real names and that the public has a legitimate interest in transparency when a federal agency is accused of unlawful retaliation. Because Benloss said he would provide supporting legal authority and factual information in a forthcoming motion, the court allowed him an opportunity to do so.
Effect of the order
The order concerns the procedure for identifying the plaintiff in the court filings. It does not decide the underlying retaliation allegations or the ultimate request to proceed under a pseudonym.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.