Doe v. American University

Summary

The United States District Court for the District of Columbia granted in part and denied in part the plaintiff’s motions to proceed pseudonymously and to file materials under seal. The court permitted the plaintiff and certain nonparties to remain pseudonymous and authorized limited redactions concerning identifying information, medical records, and details that could reveal their identities. It declined without prejudice to rule on sealing materials not yet filed and ordered the plaintiff to file a sealed declaration containing his real name and residential address.

Holdings

1. Doe may proceed pseudonymously because his privacy and safety interests arising from allegations of sexual assault and serious mental-health consequences outweigh the public's presumptive interest in disclosure of his identity.
2. Roe and the other students involved in the investigation may remain pseudonymous because the same privacy and reputational interests supporting Doe's anonymity apply to those private non-parties under the unusual circumstances of the case.
3. The court granted the request to seal or redact portions of the psychiatric evaluation and complaint that could identify the pseudonymous parties, including personal health information, contact details, specific dates and event descriptions, and hyperlinks to identifying news articles.
4. The court declined to rule on requests to seal recordings, images, and other materials not yet filed, denying that portion of the motion without prejudice.

Questions Presented

1. Whether Doe should be permitted to litigate under a pseudonym, and whether the pseudonym protection should extend to Roe and other student non-parties.
2. Whether specified portions of Doe's psychiatric evaluation and complaint should be sealed or redacted to protect the identities and privacy of the pseudonymous parties.
3. Whether the court should rule at this stage on requests to seal future recordings, images, and other documents not yet filed on the docket.

Disposition

other