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Reason
Reason
Politics
Eugene Volokh

No Pseudonymity in Case Alleging Disability Discrimination Based on "Major Depressive Disorder"

From Doe v. Medical Univ. of S.C., decided today by Magistrate Judge Mary Gordon Baker (D.S.C.):

Plaintiff John Doe, proceeding pro se, filed this civil action on May 31, 2022. Plaintiff alleges that he was improperly dismissed from Defendant Medical University of South Carolina College of Medicine on account of mental health issues he experienced following a traumatic brain injury. More specifically, Plaintiff claims he suffered from Major Depressive Disorder that prevented him from fulfilling certain program requirements, and that Defendant Medical University of South Carolina College of Medicine failed to provide guidance and make appropriate accommodations for him. [Plaintiff sued for disability discrimination and other claims. -EV]

To preserve the public's interest in judicial proceedings, there is a general presumption that an action should be prosecuted in the names of the real parties involved. The Federal Rules of Civil Procedure require that the identities of parties to a case be disclosed. See Fed. R. Civ. P. 10(a) ("The title of the complaint must name all the parties …"); Fed. R. Civ. P. 17(a) (requiring that an action "be prosecuted in the name of the real party in interest"). As such, when a party seeks to litigate under a pseudonym, the Court must "ensure that extraordinary circumstances support such a request by balancing the party's stated interest in anonymity against the public's interest in openness and any prejudice that anonymity would pose to the opposing party." In making this determination, the Court should consider:

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