In a ruling issued yesterday by U.S. District Judge Laurie J. Michelson (E.D. Mich.) in Doe v. Regents of Univ. of Mich.:
The plaintiff, a student at the University of Michigan, faced disciplinary action after she provided what the University described as a purportedly forged telehealth medical note to secure an accommodation for her coursework. The University treated this as academic dishonesty, resulting in the plaintiff’s suspension for the Winter 2026 semester and the addition of a disciplinary notation to her transcript. The plaintiff contends that the note is genuine and has sued numerous University of Michigan officials and Academic Affairs staff, alleging violations of due process.
Simultaneously, the plaintiff moved to proceed under the pseudonym “Jane Doe.” She asserts that “this case challenges discipline imposed by a public university that is based on, and would necessarily litigate, [her] private medical information and education records.” Moreover, she states that “[p]ublic disclosure of [her] identity would cause concrete and irreparable harm, including stigma associated with an ‘academic dishonesty’ finding and enduring damage to [her] educational and professional prospects due to disclosure of protected health information, including her pending graduate and professional school applications.”
Nevertheless, like other stigma-plus due process claims, this type involves the disclosure of sensitive or stigmatizing information. The plaintiff’s discomfort with that fact is not, on its own, sufficient to permit anonymous pursuit of the case, even if the defense does not oppose the request….
“Lawsuits are public events.” Generally, “a complaint must state the names of the parties.” But the Court “may excuse [parties] from identifying themselves in certain circumstances.” “In exercising its discretion, a court must balance the public’s common law right of access to court proceedings against the interests of litigants in nondisclosure.” … “The burden rests with Plaintiff to establish that it is appropriate to permit [her] to proceed under a pseudonym.” Plaintiff fails to carry that burden here….
The plaintiff simply asserts, in conclusory fashion, that “the case necessarily involves information of the utmost intimacy, including Plaintiff’s private medical circumstances, treatment, and documentation, as well as education records protected by law and custom.” But not all medical or educational information is “of the utmost intimacy.” The plaintiff does not provide any authority to support that insomnia and a finding of academic dishonesty are of the utmost intimacy. In fact, there is substantial case law to support that they are not…. [M]ost “college students challenging disciplinary procedures are required to proceed in their own name” ….
Nor is it obvious that the plaintiff’s case will, as she suggests, “necessarily litigate, Plaintiff’s private medical information.” The heart of this case is whether the plaintiff submitted a forged medical accommodation letter—not whether the plaintiff does or does not have legitimate medical needs.
Similarly, the plaintiff’s argument that an “academic dishonesty finding” threatens her professional future is not a legally cognizable consideration …. See Doe v. Univ. of Akron (N.D. Ohio 2016) (collecting cases where courts denied requests by plaintiffs faced with academic dishonesty allegations who claim “damage to [their] reputation” and concerns about “career opportunities”)….
This conclusion is not altered by the plaintiff’s contention that the defendants will not be prejudiced if the Court allowed her to proceed under a pseudonym. “[T]hat consideration alone is insufficient to outweigh compliance with the civil rules of procedure and preference for open judicial proceedings.”
The Court appreciates the plaintiff’s situation. But many federal court plaintiffs, especially those asserting stigma-plus due process claims, must face disclosure of sensitive or personal information that they would likely prefer to keep private. The plaintiff fails to carry her burden to show that her case is otherwise exceptional….
