From Doe v. Simons, decided July 29 by Judge Nicholas Ranjan (W.D. Pa.):
Plaintiff John Doe has moved to proceed under a pseudonym. Doe advances three main bases for anonymity: his mental illness; that requiring him to litigate under his own name would deter him, and similarly situated individuals, from pursuing litigation; and that his HIPAA-protected medical records would become public….
Doe has not shown that he faces a reasonable fear of severe harm. Doe’s case appears to be a straightforward employment-discrimination case. And where plaintiffs allege a fear of severe harm (namely heightened mental illness symptoms and stigma) in ordinary employment-discrimination cases, like this case, courts have denied motions to proceed under a pseudonym. See Doe v. Coll. of New Jersey (3d Cir. 2021) (affirming district court’s denial of plaintiff’s motion to proceed pseudonymously where the district court … “observed that, with regard to a need for anonymity, [plaintiff’s] case was not meaningfully different from other employment disputes”). This Court has seen many cases like this one, and recognizes that litigation often takes a toll on a party’s mental health on both sides of the “v.”
But the mental-health effects of litigation are, in a sense, the cost of doing business. Doe has not shown the Court that the mental-health effects of this particular lawsuit are so exceptional compared to other similar cases where plaintiffs have proceeded under their legal names. See Kimberly Davis v. Surefire Hospitality Group (W.D. Pa. 2026) (“[T]he distress [here] is more properly characterized as embarrassment or discomfort, which the Third Circuit has found to be insufficient to meet the standard. Without particularized allegations, Plaintiff’s request reflects a personal preference, rather than a reasonable fear or severe harm.”)….
[O]ne of [Doe’s] main concerns is that his sensitive, HIPAA-protected medical information will be publicly disclosed. But the Court has already granted several of Doe’s motions to file documents under seal. And many similarly situated individuals have filed lawsuits within this district. The Court stresses one of the most important [factors related to pseudonymity litigation]—that there is a universal public interest in the identities of litigants—and notes that this factor significantly outweighs Doe’s alleged fear of severe harm….
