Doe v. New York University
- Sidney Stein
- 1:21-cv-02199
- U.S. District Court · Southern District of New York
- 3
In Jane Doe v. New York University, Judge Stein dismissed Doe’s redaction motion as moot and granted her pseudonym motion pending the preliminary-injunction hearing.
Jane Doe may proceed under a pseudonym pending the preliminary-injunction hearing. Her request to redact identifying information from specified complaint exhibits was dismissed as moot because the information had already been redacted. New York University is the defendant in the underlying case.
What happened
In Jane Doe v. New York University, Jane Doe asked the court to redact identifying information from several exhibits attached to her complaint. She also asked to proceed under a pseudonym.
Doe’s lawsuit alleges that New York University breached a New York contract by suspending her for attending a private, off-campus dinner during the COVID-19 pandemic. She said the university’s pandemic disciplinary policy did not cover off-campus activities. The exhibits had been exchanged during a confidential student-conduct proceeding.
The exhibits had already been filed with Doe’s identifying information redacted, so Judge Sidney H. Stein dismissed the redaction motion as moot. He granted Doe’s motion to proceed under a pseudonym pending the hearing on her request for a preliminary injunction.
The detailed version
- Doe v. New York University · No. 1:21-cv-02199
- Sidney Stein
- Mar. 15, 2021
Background
Jane Doe, described in the filing as a freshman undergraduate, filed a diversity action against New York University (NYU). She alleges that NYU breached a New York State contract by failing to follow its student-conduct procedures when it immediately suspended her. According to the filing, NYU suspended her after she attended a private, off-campus dinner with seven other people who had tested negative for COVID-19. Doe alleges that NYU’s pandemic-related disciplinary policy did not apply to off-campus activities.
Along with her complaint, Doe requested a temporary restraining order and preliminary injunction to prevent NYU from imposing discipline and enforcing the suspension. She also moved under Federal Rule of Civil Procedure 10(a) to proceed under a pseudonym. The letter motion addressed in this order asked the court to redact Doe’s personally identifying information from Exhibits C, G, H, and J attached to the complaint.
Redaction Request
Doe’s filing stated that the exhibits had been exchanged during a confidential student-conduct proceeding under NYU’s student-conduct procedures. She sought redaction of information identifying her, including her identity and email address. She argued that public disclosure could cause unnecessary attention and ridicule, discourage similarly situated students from bringing lawsuits, and undermine the protection of her procedural rights.
The filing discussed the standard for sealing or restricting access to judicial documents, including the presumption of public access and the need for specific findings showing that restricting access is essential to protect higher values and narrowly tailored to that interest. It argued that the exhibits’ identifying information was not necessary to understand the litigation because the complaint described the relevant information without revealing those details.
Ruling
The order states that Exhibits C, G, H, and J had been filed with Doe’s personal identifying information already redacted. On that basis, Judge Sidney H. Stein dismissed the letter motion as moot. The order separately granted Doe’s motion to proceed under a pseudonym pending the hearing on the motion for a preliminary injunction. The text provided does not state a ruling on the preliminary-injunction request itself.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.