I wrote earlier today about a Title IX lawsuit against a university by a student who had been accused by a classmate of rape; had been exonerated by the university; but continued to be publicly accused, including by the co-presidents of a student group called "Preventing Sexual Assault." The court allowed the Title IX claim to go forward, on the theory that the continued accusations may themselves have constituted sexual harassment of the student, and that the university may not have done enough to prevent the consequent harm to the student's educational opportunities.
The student, who sued as a John Doe, had also sued the co-presidents of the student group for defamation, and had named them in the Complaint. As a general matter, most (though not all) courts let Title IX plaintiffs who claim to have been falsely accused of sexual assault sue as Does. A common theory is that the underlying Title IX proceedings are supposed to be confidential, so lawsuits over Title IX should be as well. Most courts do not allow defamation plaintiffs to sue pseudonymously, including in cases stemming from campus sexual assault accusations (see Doe v. Doe (4th Cir. 2023)), at least when they sue just for defamation. (Query what the right result is when, as here, the plaintiffs sue both under Title IX and for defamation.)
But here the question was about the naming of the defendant student group co-presidents. The plaintiff originally sued them by name, but three months later the parties agreed to have those defendants pseudonymized, and the court approved that (without any detailed explanation). Here's an excerpt from their motion:
