B. v. Brooks-Lasure
- William Alsup
- 3:22-cv-04501
- U.S. District Court · Northern District of California
- 2
In B. v. Brooks-Lasure, Judge Alsup granted plaintiffs’ motion to proceed under pseudonyms because their medical privacy interests outweighed disclosure concerns.
The order affects the plaintiffs and their conservators, who may proceed under pseudonyms, and the defendants and public, who will not have access to the plaintiffs’ identities through the public case caption.
What happened
B. v. Brooks-Lasure is a putative class action by residents of a skilled nursing facility who claim that defendants unlawfully relocated them and others. The plaintiffs asked to use pseudonyms, and defendants did not oppose the request on time.
The court found that each plaintiff had a severe mental disability or an uncommon medical condition, making the information involved highly personal and sensitive. It also found that using pseudonyms would not prejudice defendants and would still allow the public to understand the relevant facts.
The court ruled that the plaintiffs’ need for anonymity outweighed the public’s interest in knowing their identities and any prejudice to defendants. Judge Alsup granted the motion, allowing the plaintiffs and their conservators to proceed under pseudonyms.
The detailed version
- B. v. Brooks-Lasure · No. 3:22-cv-04501
- William Alsup
- Aug. 17, 2022
Background
The plaintiffs brought a putative class action against Chiquita Brooks-Lasure, the California Department of Public Health, Tomas Aragon, Xavier Becerra, and other defendants. The opinion says the plaintiffs claim that defendants were and are relocating them and other residents of a skilled nursing facility in violation of state and federal law.
The named plaintiffs include D. B. as conservator for John Doe 1, C.C. as guardian for Jane Doe 1, John Doe 2, and Jane Doe 2. They asked to proceed using pseudonyms for themselves and their conservators.
Analysis
The court applied the rule that a party may remain anonymous in special circumstances when the need for anonymity outweighs prejudice to the opposing party and the public interest in knowing the party’s identity. Courts may allow pseudonyms when anonymity is necessary to protect privacy involving sensitive and highly personal matters.
The court found that each plaintiff had either a severe mental disability, including brain injury, dementia, or depression, or an uncommon medical condition, including compulsive behavior, brittle diabetes, or hemorrhagic stroke. The court concluded that the related mental-health information and medical diagnoses supported anonymity.
The court also found no prejudice to defendants. It stated that the plaintiffs’ identities were not necessary to determine the effects of administrative action requiring closure and relocation on a large group of people with disabilities and medical conditions. The court further concluded that the public could access the relevant facts without knowing the plaintiffs’ identities and had an interest in ensuring that privacy concerns did not discourage people with mental disabilities from bringing lawsuits.
Disposition
Defendants did not oppose the motion for administrative relief within the time allowed by Civil Local Rule 7-11(b), so the motion was deemed submitted for immediate determination. The court held that the plaintiffs’ need for anonymity outweighed the public’s interest in their identities and any prejudice to defendants. Judge William Alsup granted the plaintiffs’ motion to proceed under pseudonyms. The opinion does not decide the merits of the plaintiffs’ claims about relocation.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.