C.S. v. Stay Inn, et al.

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OHIO
WESTERN DIVISION
C.S., 	CASE NO. 3:25 CV 2322
Plaintiff,
v. 	JUDGE JAMES R. KNEPP II
STAY INN, et al.,
Defendants. 	ORDER
Currently pending before the Court are motions contesting whether Plaintiff, currently
identified only as “C.S.,” should be permitted to proceed pseudonymously in this case. See Docs.
3, 7, 8. For the following reasons, the Court grants Plaintiff’s request to proceed pseudonymously.
As a rule, actions must be prosecuted in the name of the real party in interest, Fed. R. Civ.
P. 17(a)(1), and a complaint must state the names of the parties, Fed. R. Civ. P. 10(a). “Plaintiffs
are permitted to proceed under pseudonyms only under certain circumstances that justify an
exception to this rule.” Citizens for a Strong Ohio v. Marsh, 123 F. App’x 630, 636 (6th Cir. 2005)
(referring to Rule 10(a)). Whether to allow a party to proceed under a pseudonym is committed to
the sound discretion of the Court but should be permitted only if the privacy interests of the party
seeking anonymity substantially outweigh the strong presumption in favor of open judicial
proceedings. Doe v. Porter, 370 F.3d 558, 560 (6th Cir. 2004).
This determination is informed by several, non-exclusive considerations, including: (1)
whether the plaintiff seeking anonymity is suing to challenge governmental activity; (2) whether
prosecution of the suit will compel the plaintiff to disclose information of the utmost intimacy; (3)
whether the litigation compels plaintiff to disclose an intention to violate the law, thereby risking
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criminal prosecution; and (4) whether the plaintiff is a child. Id. (quoting Doe v. Stegall, 653 F.2d
180, 185-86 (5th Cir. 1981)). In arriving at its conclusion, the Court must “start from the premise
that proceeding pseudonymously is the exception rather than the rule.” Doe v. Franklin Cnty., 2013
WL 5311466, at *2 (S.D. Ohio) (citation omitted). “Other factors that may be considered include
whether the plaintiff would risk suffering injury if identified and whether the defendant would be
prejudiced by the plaintiff’s proceeding anonymously.” Doe v. FedEx Ground Package Sys., Inc.,
2021 WL 5041286, at *5 (M.D. Tenn.) (citations omitted).
The parties agree only the second factor – that the suit will compel Plaintiff to disclose
information of the “utmost intimacy” – is at issue here. See Doc. 7, at 4; Doc. 8, at 3.
“[A] district court has discretion to allow a plaintiff to proceed anonymously when that
‘plaintiff’s 	privacy 	interests 	substantially 	outweigh 	the 	presumption 	of 	open 	judicial
proceedings.’” Doe v. St. Edward High Sch., 2022 WL 2717018, at *3 (N.D. Ohio) (quoting
Porter, 370 F.3d at 560). And “[m]any federal courts have exercised this discretion to authorize
fictious names for plaintiffs who are sexual assault victims because their cases involve information
of the ‘utmost intimacy.’” Id. (collecting cases); see also Doe v. Blue Cross & Blue Shield United
of Wis., 112 F.3d 869, 872 (7th Cir. 1997) (“[F]ictitious names are allowed when necessary to
protect the privacy of children, rape victims, and other particularly vulnerable parties or
witnesses.”); Doe v. Athens Cnty., 2022 WL 787868, at *1 (S.D. Ohio) (“Courts throughout the
country have routinely found that the privacy interests of alleged sexual assault victims outweigh
the presumption in favor of openness.”). As Plaintiff points out, courts have at times allowed a
plaintiff to proceed pseudonymously “even when a plaintiff’s immediate community knows about
sexual assault allegations generally” in order “to mitigate the additional trauma of having his name
and assault committed to the public record.” St. Edward High Sch., 2022 WL 2717018, at *4
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(citation omitted). To be sure, as Defendants point out, other courts have found the opposite. See,
e.g., Doe v. Wolowitz, 2002 WL 1310614, at *2 (E.D. Mich).
In this case, Plaintiff brings suit against her former employer alleging she was sexually
assaulted by her supervisor at her place of employment. See Doc. 1. She brings a federal claim for
violations of Title VII of the Civil Rights Act of 1984, as well as claims under Ohio state law. She
seeks to proceed pseudonymously, asserting publicity of her identity “will cause further
unwarranted trauma to her.” Id. at 1. Plaintiff further asserts her identity is known to Defendants.
Id. Here, Plaintiff has presented a sufficient basis for the Court to conclude her privacy interest
substantially outweighs the presumption of open court proceedings.
For the foregoing reasons, good cause appearing, it is
ORDERED that Plaintiff’s Motion for Protective Order (Doc. 3), and Cross-Motion to
Proceed Pseudonymously (Doc. 8) be, and the same hereby are, GRANTED; and it is
FURTHER ORDERED that Defendants’ Motion to Dismiss (Doc. 7) be, and the same
hereby is, DENIED.
s/ James R. Knepp II
UNITED STATES DISTRICT JUDGE
Dated: January 9, 2026
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