Doe v. Columbia University

Background

John Doe filed the complaint in this case using a pseudonym, meaning a name other than his actual name. The court cited Federal Rule of Civil Procedure 10(a), which generally requires a complaint to name all parties. The court explained that this requirement promotes public review of court proceedings and should not be set aside lightly.

Pseudonym request

The court described the factors courts consider when deciding whether a plaintiff may proceed anonymously. These include whether the case involves highly sensitive personal matters; whether anonymity would unfairly harm or disadvantage the defendant and whether that harm could be reduced; whether the plaintiff’s identity has remained confidential; and whether requiring disclosure would serve the public interest. The court also noted that possible physical or mental injury from identification may be relevant.

Ruling and deadlines

The court did not decide whether John Doe could proceed anonymously. Instead, Judge Gregory H. Woods ordered him to show cause—meaning to explain—by September 1, 2020, why he should be allowed to proceed pseudonymously. If Columbia University opposed the request, its opposition was due one week after service of the plaintiff’s response. Any reply was due three days after service of the opposition. The court directed the plaintiff’s counsel to serve the order on Columbia University and keep proof of service.