Doe v. Columbia University in the City of New York
- Analisa Torres
- 1:22-cv-10340
- U.S. District Court · Southern District of New York
- 2
Doe v. Columbia University, Judge Torres granted Jane Doe’s motion to proceed under a pseudonym in her sexual-assault case.
Jane Doe may proceed under a pseudonym, while the defendants and the public will not have her identity disclosed in the case at this time.
What happened
In Doe v. Columbia University in the City of New York, Jane Doe sued Columbia University, New York and Presbyterian Hospital, and unnamed defendants concerning the alleged sexual assault and the defendants’ handling of it.
Doe asked to keep her identity confidential, arguing that the case involved highly personal matters, that disclosure could cause mental harm, and that the defendants and public would not be unfairly harmed. The defendants did not oppose the request.
Judge Torres granted the motion, finding that Doe’s privacy and safety interests outweighed the public interest in knowing her identity at that time. The court also noted that the defendants already knew who she was and that she had taken steps to keep her identity confidential.
The detailed version
- Doe v. Columbia University in the City of New York · No. 1:22-cv-10340
- Analisa Torres
- Jan. 3, 2023
Background
Jane Doe brought this action against Columbia University in the City of New York, the New York and Presbyterian Hospital, and unnamed defendants. She alleged that the case concerned sexual abuse by her gynecologist, Robert Hadden. The court ordered Doe to request permission to proceed under a pseudonym, and she filed that request. The defendants did not oppose it.
Legal standard
Federal Rule of Civil Procedure 10(a) generally requires a complaint to name all parties. Courts may make limited exceptions when a plaintiff seeks to proceed anonymously. The court must balance the plaintiff’s interest in anonymity against the public interest in disclosure and any prejudice to the defendants. Relevant considerations include the sensitivity of the subject matter, possible physical or mental harm from identification, the plaintiff’s vulnerability, prejudice to the defendants, whether the identity has been kept confidential, the public interest in disclosure, and whether other confidentiality protections are available.
Court’s analysis
The court found that allowing Doe to use a pseudonym was appropriate. The litigation concerned the defendants’ handling of an alleged sexual assault, which involved highly sensitive and personal matters. The complaint alleged that Doe experienced pain, trauma, distress, and suffering, and the court found a risk that disclosure of her identity could cause the very harm she was seeking to litigate.
The court also considered that the defendants knew Doe’s identity and did not oppose the request. Doe had taken steps to maintain confidentiality, including not speaking publicly about the incidents underlying her claims. At that time, the court concluded that Doe’s interest in anonymity outweighed the public interest in disclosure.
Disposition
Judge Analisa Torres granted Doe’s motion to proceed under a pseudonym. The Clerk of Court was directed to terminate the motions at ECF Nos. 12, 13, and 14. This order addressed anonymity and did not decide the underlying claims.
Classification
This is a procedural order because the court ruled on the ancillary issue of whether Doe could litigate under a pseudonym, rather than deciding the merits of her claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.