Doe, a student in Yale Law School's Doctor of Juridical Science ("J.S.D.") program, sued Yale University, Director of Student Accessibility Services Kimberly McKeown, and Assistant Dean for Graduate Programs Gordon Silverstein (collectively, "Yale"), alleging [disability] discrimination and retaliation … as well as breach of contract. Doe primarily claimed that Yale improperly refused to extend her J.S.D. candidacy for an additional year—which she believes she needs in order to produce a dissertation of sufficient quality—and sought injunctive relief barring Yale from discharging her from the program.

The same day that she filed her complaint, Doe moved for an order permitting her to proceed by pseudonym. She asserted that her identification as plaintiff in this lawsuit would diminish her academic and employment opportunities because the case would necessarily disclose details concerning her diagnosed medical conditions, her medical treatment history, and the impact of her conditions on her academic performance. She also contended that "[p]ublic disclosure of [her] identity would likely exacerbate her existing psychiatric conditions" and subject her to "stigma associated with mental health conditions."

On June 17, 2025, the district court denied the motion in an order that identified and applied several factors articulated by our Court in Sealed Plaintiff v. Sealed Defendant (2d Cir. 2008). In so doing, the court noted that it had taken steps to protect her privacy by sealing Doe's private medical information.

Doe's motion for reconsideration, filed three days later, added an affidavit from Doe and a letter from her psychiatrist of nine years, which substantiated Doe's claim that disclosure would risk serious mental harm. Because the new evidence attached to the motion "could have been raised earlier," the court declined to consider it and denied the motion. The district court's denials of both orders were proper.

The district court properly denied Doe's initial motion to proceed by pseudonym. We review a district court's decision to grant or deny a motion to proceed under a pseudonym for abuse of discretion. A district court abuses its discretion when it "bases its ruling on an erroneous view of the law or on a clearly erroneous assessment of the evidence or when its decision—though not necessarily the product of a legal error or a clearly erroneous factual finding—cannot be located within the range of permissible decisions."

Federal Rule of Civil Procedure 10(a) directs that "[t]he title of [a] complaint must name all the parties." This requirement "serves the vital purpose of facilitating public scrutiny of judicial proceedings and therefore cannot be set aside lightly." Courts have, however, "carved out a limited number of exceptions to the general requirement of disclosure of the names of parties, which permit plaintiffs to proceed anonymously."

Courts determine whether a plaintiff may proceed under a pseudonym by balancing "the plaintiff's interest in anonymity … against both the public interest in disclosure and any prejudice to the defendant." … Ultimately, "pseudonyms are the exception and not the rule, and in order to receive the protections of anonymity, a party must make a case rebutting that presumption." Contrary to Doe's contentions, the district court identified the relevant factors and undertook a reasoned, clearly-articulated analysis of the pertinent considerations…. Its decision therefore reflects a proper exercise of its discretion….

Here's an excerpt from the decision that the court affirmed: Plaintiff's medical condition and the accommodations she sought as a result thereof are at the heart of this case and indeed appear in the first sentence of the sealed complaint. Nonetheless, "'[t]he fact that a case involves a medical issue is not a sufficient reason for allowing the use of a fictitious name." Otherwise, every ADA plaintiff would be entitled to proceed pseudonymously.

In this case, the court has sealed Plaintiff's private medical information, and finds that Defendants have been respectful of that fact (at oral argument, in docketing protected material under seal, and in eliciting testimony and evidence). Defendants also do not appear to dispute that Plaintiff is disabled within the meaning of the relevant statutes. Thus, Plaintiff's privacy has been protected to date, and the court finds that this is likely to continue.

For similar reasons, and also in light of the accommodations provided by Defendants to date, the court finds that Plaintiff's claim of vulnerability to future discrimination (due to the publication of her identity) is entirely speculative. Whether Defendants previously discriminated against her, a