Doe v. Sarah Lawrence College

Background

John Doe moved for permission to proceed under a pseudonym and to identify another student as “Jane Roe” in an action involving allegations of sexual assault. He also sought a protective order preventing Sarah Lawrence College from disclosing his identity. The motion was unopposed.

Legal standard

Federal Rule of Civil Procedure 10(a) generally requires a complaint to name all parties. The court explained that a plaintiff may use a pseudonym in special circumstances when the need for anonymity outweighs prejudice to the opposing party and the public’s interest in knowing the plaintiff’s identity. Courts consider factors including the sensitivity of the subject matter, possible harm from disclosure, the plaintiff’s vulnerability, prejudice to the defendant, whether the identity has remained confidential, the public interest in disclosure, and alternative ways to protect confidentiality.

Court’s analysis

The court determined that the case involved highly sensitive and personal matters because the complaint concerned a private educational institution’s handling of an alleged sexual assault. It stated that public exposure could be personally damaging to both the alleged victim and the accused, that disclosure of the alleged victim’s identity could cause psychological trauma, and that protecting identities could serve the public interest in encouraging victims to report similar crimes. The court also found that Sarah Lawrence College would not be prejudiced by the use of pseudonyms.

Ruling

The court granted the motion. John Doe was permitted to proceed under that pseudonym, the alleged victim was to be identified as Jane Roe, and Sarah Lawrence College, including its agents, employees, and representatives, was ordered not to disclose Doe’s or Roe’s identities in court filings or otherwise. The order addressed anonymity and confidentiality; the opinion did not decide the underlying allegations.