LEWISTON PUBLIC SCHOOLS v. SPURWINK SERVICES INC et al

UNITED STATES DISTRICT COURT
DISTRICT OF MAINE
LEWISTON PUBLIC SCHOOLS, 	)
)
Plaintiff 	)
)
v. 	) 	2:26-cv-00019-JAW
)
SPURWINK SERVICES, INC., et al., 	)
)
Defendants 	)
ORDER ON PLAINTIFF’S MOTION
TO PROCEED UNDER PSEUDONYMS
In this action, Plaintiff asks the Court to determine that Defendant Spurwink
Services, Inc., must readmit a student who is eligible to receive special education and
related services under the Individuals with Disabilities Education Act (IDEA). 	Plaintiff
has joined as defendants the student and the student’s parents. Plaintiff asks the Court to
permit the student and the student’s parents to proceed under pseudonyms and to seal
certain documents. 	(Motion to Proceed Under Pseudonyms, ECF No. 3.) 	None of the
defendants has filed an opposition to the motion.
Following a review of the record and after consideration of the issues generated by
Plaintiff’s motion, the Court grants the motions.
DISCUSSION
Generally, the “title of [a] complaint must name all the parties.” 	Fed. R. Civ. P.
10(a); see also, Fed. R. Civ. P. 17(a)(1) (“[a]n action must be prosecuted in the name of
the real party in interest.”) Courts, however, have recognized exceptions to this rule, and
under certain circumstances have permitted a party to proceed under a pseudonym. 	The
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First Circuit described the analysis that should govern a trial court’s assessment of a request
to proceed under a pseudonym:
A district court adjudicating a motion to proceed under a pseudonym should
balance the interests asserted by the movant in favor of privacy against the
public interest in transparency, taking all relevant circumstances into account.
In most cases, the inquiry should focus upon the extent to which the facts align
with one or more of the following paradigms: whether the case is one in which
the movant reasonably fears that coming out of the shadows will cause him
unusually severe physical or mental harm; whether the case is one in which
compelled disclosure of the movant's name will likely lead to disclosure of a
nonparty's identity, causing the latter substantial harm; whether the case is one
in which compelled disclosure would likely deter, to an unacceptable degree,
similarly situated individuals from litigating; or whether the federal suit is
bound up with a prior proceeding subject by law to confidentiality protections
and forcing disclosure of the party's identity would significantly impinge upon
the interests served by keeping the prior proceeding confidential. Because these
paradigms are framed in generalities, a court enjoys broad discretion to quantify
the need for anonymity in the case before it. This broad discretion extends to
the court's ultimate determination as to whether that need outweighs the public's
transparency interest.
Doe v. Mass. Inst. of Tech., 46 F.4th 61, 72 (1st Cir. 2022).
While the procedural rules require that Plaintiff use a pseudonym for the student’s
name, see District of Maine Local Rule 16.3(e)(3), the rules do not include a similar
requirement for the names of a student’s parents or guardians. The Court, however, may
permit a parent or guardian to proceed under a pseudonym if warranted after an assessment
in accordance with the First Circuit’s guidance in Doe v. Mass. Inst. of Tech. 	Because
disclosure of the names of the students’ parents will undoubtedly increase the likelihood
that the student’s name would become known thereby frustrating the purpose of Local Rule
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16.3(e)(3), the Court grants the motion and permits Plaintiff to proceed through use of
pseudonyms for the student’s parents.
As to Plaintiff’s request to seal documents that include the actual names of the
student and the student’s parents, the Court is not aware of any filed documents that include
the actual names. 	The Court construes the motion as a request to require a party to file
under seal any document that includes the actual names of the student and/or the students’
parents. For the same reasons the Court permits the use of pseudonyms, the Court grants
the motion.
CONCLUSION
After a review of the record, for the reasons set forth herein, the Court grants
Plaintiff’s motion to proceed under pseudonyms and to seal certain documents. The Court
orders:
1. 	Plaintiff may use pseudonyms for the student’s parents.
2. 	In accordance with Local Rule 10(d), Plaintiff shall file under seal an affidavit
disclosing the actual names of the parents.
3. 	If a party files a document that includes the actual names of the student and/or
the student’s parents, the party shall file the document under seal and file a
redacted version for the public docket.
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NOTICE
Any objections to this order shall be filed in accordance with Federal Rule of Civil
Procedure 72.
/s/ John C. Nivison
U.S. Magistrate Judge
Dated this 12th day of February, 2026.
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