Second Circuit Rejects Pseudonym Request in Yale Law Student Discrimination Case

The U.S. Court of Appeals for the Second Circuit has upheld a lower court’s decision denying a Yale Law School student’s motion to proceed under a pseudonym in her discrimination lawsuit against Yale University.

The plaintiff, identified in court filings as Jane Doe, is a student in Yale’s Doctor of Juridical Science (J.S.D.) program. She sued Yale, Director of Student Accessibility Services Kimberly McKeown, and Assistant Dean for Graduate Programs Gordon Silverstein, alleging disability discrimination, retaliation, and breach of contract. Doe claimed Yale improperly denied her an additional year to complete her dissertation, sought injunctive relief to prevent her removal from the program, and requested to proceed anonymously to protect her privacy.

Doe argued that public disclosure of her identity would harm her academic and employment prospects, expose details of her medical conditions and treatment history, and exacerbate her psychiatric conditions. She also cited the potential for stigma associated with mental health conditions. On June 17, 2025, the district court denied her motion, citing factors from the Second Circuit’s 2008 decision in Sealed Plaintiff v. Sealed Defendant and noting that it had already sealed her private medical information to protect her privacy.

Doe filed a motion for reconsideration three days later, submitting an affidavit from herself and a letter from her nine-year treating psychiatrist to support her claim that disclosure would risk serious mental harm. The district court declined to consider the new evidence, stating it “could have been raised earlier,” and denied the motion.

Second Circuit Affirms Denial of Pseudonym

The Second Circuit panel—consisting of Judges Dennis Jacobs, Richard C. Wesley, and Michael H. Park—affirmed the district court’s rulings. The appeals court reviewed the denial of Doe’s motion to proceed pseudonymously for abuse of discretion, a standard that applies when a court’s decision is based on an erroneous view of the law, a clearly erroneous assessment of evidence, or falls outside the range of permissible choices.

The court emphasized that Federal Rule of Civil Procedure 10(a) requires complaints to name all parties, stating that this rule “serves the vital purpose of facilitating public scrutiny of judicial proceedings and therefore cannot be set aside lightly.” While courts have carved out limited exceptions allowing plaintiffs to proceed anonymously, they must balance the plaintiff’s interest in anonymity against the public’s right to know and the defendant’s right to a fair trial.

The Second Circuit concluded that the district court did not abuse its discretion in denying Doe’s motion. The lower court had already taken steps to protect her privacy by sealing her medical information, and the plaintiff failed to demonstrate that the public disclosure of her identity would cause harm sufficient to justify overriding the strong presumption in favor of open judicial proceedings.