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Doe v. Sessions

United States District Court, District of Columbia

September 27, 2018

JOHN DOE, Plaintiff,
JEFFERSON B. SESSIONS, et al. Defendant.



         Granting Plaintiff's Motion to File Under a Pseudonym


         The Plaintiff in this action-who alleges, among other claims, that he was discriminated against by the Federal Bureau of Investigation (the “FBI”) based on his mental disability-has moved to proceed under a pseudonym. He asserts that public association of his name with this action would subject him to “severe emotional trauma” resulting from the disclosure of a sensitive diagnosis that he has kept confidential for decades. For the reasons set forth below, this Court grants Plaintiff's motion.


         Plaintiff, who suffers from Asperger's Syndrome, Acute Stress Disorder, Panic Disorder, post-traumatic stress disorder (“PTSD”), and anxiety, asserts a variety of claims against the United States Attorney General and three FBI employees (“Defendants”) arising from his FBI employment and termination. Compl. ¶ 5. Plaintiff was employed by the FBI for approximately twenty-five years as a Personal Security Specialist responsible for processing visitor access requests for access to FBI facilities. Id. ¶¶ 11-12. He alleges that from early- to mid-2015, he participated in meetings and department exercises in which he was at various points ridiculed, threatened, and falsely accused of violating FBI procedures. Id. ¶¶ 14-19. This alleged harassment caused Plaintiff to experience panic attacks and other conditions which required him to take multiple sick leaves throughout the summer and fall of 2015. Id. ¶¶ 20, 25. When Plaintiff returned from his leaves, he alleges that his supervisors “singled him out, ” constructively demoted him, withheld access to necessary training, and continued to harass and publicly humiliate him, causing additional mental trauma. Id. ¶¶ 20-41. Finally, Plaintiff alleges that when he sought reasonable accommodations for his mental conditions, the FBI's Reasonable Accommodation Program Coordinator unnecessarily disclosed Plaintiff's confidential medical documentation-including his Asperger's diagnosis-to his supervisors. Id. ¶¶ 44-46. According to Plaintiff, the FBI failed to provide him with reasonable accommodations and ultimately terminated him because of his disabilities. Id. ¶¶ 71-83.

         Having exhausted his administrative remedies, Plaintiff commenced the present action in the United States District Court for the District of Maryland, alleging a hostile work environment, denial of reasonable accommodations for his disabilities, discriminatory termination, and breach of confidentiality through disclosure of his medical information. See generally id. He argues that these actions violated the Rehabilitation Act and his constitutional rights, and he seeks declaratory relief, injunctive relief, and damages. Id. ¶ 1; id. at 26-27.

         On the same date that Plaintiff filed the complaint he filed a motion to proceed under a pseudonym, citing his “severe mental trauma, ” his “right to confidentiality of medical information, ” and his “sensitive position with the FBI that required security clearance.” Pl.'s Mot. to File under a Pseudonym (“Pl.'s Mot.”), ECF No. 2. Defendants never responded to Plaintiff's motion, and Plaintiff has filed several documents under the pseudonym during the past three years of this litigation without protest from Defendants.

         On January 1, 2018, the case was transferred from the District of Maryland to this Court. Upon prompting from this Court, and despite previously failing to object to Plaintiff's pseudonymous filings, Defendants opposed Plaintiff's motion to proceed under a pseudonym. Accordingly, that motion is now ripe and, for the reasons stated below, the Court will grant it.


         Generally, a complaint in federal court must state the names of the parties. Fed.R.Civ.P. 10(a) (“The title of the complaint must name all the parties”); LCvR 5.1(c)(1) (“The first filing by or on behalf of a party shall have in the caption the name and full residence address of the party, ” and “[f]ailure to provide the address information within 30 days of filing may result in the dismissal of the case against the defendant.”); LCvR 11.1 (same requirement as LCvR 5.1(c)(1)). The public's interest “in knowing the names of . . . litigants” is crucial because “disclosing the parties' identities furthers openness of judicial proceedings.” Doe v. Pub. Citizen, 749 F.3d 246, 273 (4th Cir. 2014); see also Nixon v. Warner Commc'ns, Inc. 435 U.S. 589, 597 (1978) (“[T]he courts of this country recognize a general right to inspect and copy public records and documents, including judicial records and documents.”). Nevertheless, courts have, in special circumstances, permitted a party to “proceed anonymously” when a court determines that “the impact of the plaintiff's anonymity” outweighs “the public interest in open proceedings and on fairness to the defendant.” Nat'l Ass'n of Waterfront Emp'rs v. Chao (“Chao”), 587 F.Supp.2d 90, 99 (D.D.C. 2008).

         In the past, when balancing these two general factors, two different but analogous tests have applied in this circuit to sealed and anonymous filings. The first test consists of the six factors set forth in United States v. Hubbard, 650 F.2d 293, 317-21 (D.C. Cir. 1980), governing sealed filing:

(1) the need for public access to the documents at issue; (2) the extent to which the public had access to the document prior to the sealing order; (3) the fact that a party has objected to disclosure and the identity of the objecting party; (4) the strength of the property and privacy interests involved; (5) the possibility of prejudice to those opposing disclosure; and (6) the purpose for which the documents were introduced.

Doe v. CFPB (“Doe I”), No. 15-1177, 2015 WL 6317031, at *2 (D.D.C. Oct. 16, 2015). The second test consists of five factors drawn from Chao ...

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