John Doe v. Columbia University
- James Oetken
- 1:19-cv-11328
- U.S. District Court · Southern District of New York
- 2
In John Doe v. Columbia University, Judge Oetken denied reconsideration, kept the complaint sealed, and ordered pseudonyms for nonparties.
John Doe, the Trustees of Columbia University in the City of New York, and the nonparties whose names appeared in the case materials.
What happened
John Doe v. Trustees of Columbia University in the City of New York involved Doe’s request to reconsider an earlier order requiring the complaint and documents naming certain nonparties to remain sealed.
The court found that Doe had not shown a change in controlling law, new evidence, clear error, or a need to prevent serious unfairness. The court therefore denied the request, and the complaint remained sealed.
Judge Oetken also ordered the names of the nonparties to be replaced with pseudonyms until further order and directed the parties to prepare a version of the complaint using those pseudonyms.
The detailed version
- John Doe v. Columbia University · No. 1:19-cv-11328
- James Oetken
- Jan. 22, 2020
Background
The court considered letters from Plaintiff John Doe and Defendant Trustees of Columbia University in the City of New York. Doe asked the court to reconsider its December 16, 2019 Order of Service. That earlier order directed that the complaint—and other documents using the unredacted names of certain nonparties involved in sensitive and personal events described in the complaint—be sealed. The earlier order also denied Doe’s request to proceed without paying filing fees for purposes of an appeal.
Columbia opposed Doe’s request. The opinion states that Columbia asserted its official corporate name was “The Trustees of Columbia University in the City of New York” and that it was the sole defendant.
Legal standard and ruling
A motion for reconsideration requires the moving party to show an intervening change in controlling law, newly available evidence, or a need to correct clear error or prevent manifest injustice. The court concluded that Doe’s motion showed none of those grounds. It therefore denied the motion, and the complaint was to remain under seal.
The court also ordered that the names of the nonparties identified in Columbia’s December 30, 2019 letter be pseudonymized until further order. The parties were directed to meet and confer about pseudonyms, use them in future case-related filings, prepare a pseudonymized version of the complaint for filing by February 14, 2020, and file the list linking the pseudonyms to the corresponding names under seal.
Effect of the order
The reconsideration request was denied. The complaint remained sealed, and the nonparties’ names were ordered to be replaced with pseudonyms until further order. The opinion also states that a copy was mailed to the pro se party, meaning a party proceeding without a lawyer.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.