Doe v. Zeumer

Background

Jane Doe and Thomas Zeumer submitted a stipulation concerning Doe’s ability to proceed under a pseudonym. The stipulation stated that Zeumer did not object to Doe proceeding anonymously.

Legal standard

The court noted that Federal Rule of Civil Procedure 10(a) generally requires a complaint’s title to name all parties. Courts nevertheless recognize limited exceptions allowing a plaintiff to proceed under a pseudonym. The court must balance the plaintiff’s interest in anonymity against the public interest in disclosure and any prejudice to the defendant.

The court identified several considerations, including the sensitivity of the matters, possible harm from identification, the plaintiff’s vulnerability, whether the case challenges private or government conduct, potential prejudice to the defendant, whether the identity has remained confidential, the public interest in knowing the parties’ identities, and whether other confidentiality protections are available. The court explained that Defendant’s consent addressed some considerations but did not end the required analysis.

Ruling and deadlines

The court ordered that it would not approve the parties’ stipulation. It required Doe to submit a letter motion to proceed under a pseudonym by February 21, 2024, addressing the identified factors. It allowed Zeumer to respond by letter by February 26, 2024, and to state in that response, if applicable, that he did not oppose Doe’s letter motion.