No Pseudonymity for Parent Suing Over School Vaccination Mandate
The Ninth Circuit ruled that a parent, referred to as Doe, cannot proceed pseudonymously in her lawsuit against a school vaccination mandate. The court found that Doe did not demonstrate a reasonable fear of severe harm that would justify anonymity. The decision emphasized the importance of open courts and the need for plaintiffs to provide substantial evidence for their claims of vulnerability.
- ▪The court requires plaintiffs to show both a fear of severe harm and that this fear is reasonable to proceed pseudonymously.
- ▪Doe's concerns about potential social stigma were deemed insufficient to warrant anonymity.
- ▪The district court's assessment of Doe's vulnerability was not considered an abuse of discretion by the appellate court.
Opening excerpt (first ~120 words) tap to expand
Free Speech No Pseudonymity for Parent Suing Over School Vaccination Mandate Eugene Volokh | 5.21.2026 4:26 PM From today's Ninth Circuit 2-1 panel decision in Doe v. Ventura Unified School Dist., by Judge Richard Paez and Consuelo Callahan: [1.] To proceed pseudonymously, a "plaintiff must show both (1) a fear of severe harm, and (2) that the fear of severe harm is reasonable." These are the "two most important factors," id., because a plaintiff must establish "a need for the cloak of anonymity." The district court's determination that Doe failed to show she reasonably feared severe harm was not an abuse of discretion.
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Excerpt limited to ~120 words for fair-use compliance. The full article is at Reason Magazine.
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