No Pseudonymity for U Michigan Student Challenging Discipline for Using "Assertedly 'Fake' … Medical Note" "to Obtain an Accommodation"

From yesterday’s decision by Judge Laurie J. Michelson (E.D. Mich.) in Doe v. Regents of Univ. of Mich.:

Plaintiff, a student at the University of Michigan, was disciplined for providing an “assertedly ‘fake’ telehealth medical note” to obtain an accommodation for her coursework. The University treated this as academic dishonesty, resulting in Plaintiff’s suspension for the Winter 2026 semester and the inclusion of a disciplinary notation on her transcript. Plaintiff maintains that the note is genuine and filed this lawsuit against numerous University of Michigan officials and Academic Affairs employees alleging due process violations.

At the same time, Plaintiff filed a motion to proceed under the “Jane Doe” pseudonym. According to Plaintiff, “[t]his case challenges discipline imposed by a public university that is based on, and would necessarily litigate, Plaintiff’s private medical information and education records.” Moreover, continues Plaintiff, “[p]ublic disclosure of [her] identity would cause concrete and irreparable harm, including stigma associated with an ‘academic dishonesty’ finding and enduring damage to Plaintiff’s educational and professional prospects due to disclosure of protected health information, including her pending graduate and professional school applications.”

But cases raising “stigma-plus” due process claims, like this one, involve the disclosure of sensitive or stigmatizing information. Plaintiffs’ discomfort with that fact is not sufficient to permit her to proceed anonymously, even absent any opposition from the defense….

“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….

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.” 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 Plaintiff’s case will, as she suggests, “necessarily litigate, Plaintiff’s private medical information.” The heart of this case is whether Plaintiff submitted a forged medical accommodation letter—not whether Plaintiff does or does not have legitimate medical needs.

Similarly, 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 Plaintiff’s contention that 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 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. Plaintiff fails to carry her burden to show that her case is otherwise exceptional….

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