From Monday's decision in Doe v. Yale Univ., by Dennis Jacobs, Richard C. Wesley, and Michael H. Park:
Plaintiff Jane Doe appeals from an order of the district court denying her motion to proceed by pseudonym as well as the district court's order denying reconsideration. 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.
