Doe v. Archdiocese of N.Y.
2025 NY Slip Op 50338(U)
N.Y. Sup. Ct., New York Cty.2025Background:
- Plaintiff, John Doe, alleges he was the victim of sexual assault and claims significant physical, emotional, and psychological injuries.
- The lawsuit is brought under the Victims of Gender-Motivated Violence Protection Law (GMVA), which revives previously time-barred claims for gender-motivated violence.
- Doe moves for permission to proceed under a pseudonym, concerned about the stigma and further harm revealing his identity would cause.
- Defendants, Archdiocese of New York and The Church of St. John the Evangelist, were properly served but did not oppose the motion.
- The motion seeks only anonymity, not to seal the records, and there is no countervailing privacy interest asserted by defendants.
- The court must balance Doe’s request for privacy against the public’s right to open judicial proceedings and any prejudice to defendant.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Request to proceed anonymously | Public anonymity protects Doe from stigma | No opposition | Granted, Doe may proceed anonymously |
| Effect on open court and transparency | Open records maintained; only pseudonym sought | No opposition | Anonymity less restrictive than sealing |
| Legislative intent of GMVA | Revealing identity chills claims & violates law | No opposition | Anonymity supports GMVA’s purpose |
| Prejudice to defendant | Institutions have no similar privacy concern | No opposition | No prejudice to defendant found |
Key Cases Cited
- Anonymous v. Lerner, 124 A.D.3d 487 (App. Div. 1st Dept. 2015) (court discretion to balance privacy and openness in anonymity motions)
- Danco Labs. v. Chemical Works of Gedeon Richter, 274 A.D.2d 1 (App. Div. 1st Dept. 2000) (value of public access to judicial proceedings)
- Cole v. Mandell Food Stores, Inc., 93 N.Y.2d 34 (N.Y. 1999) (primary purpose of pleadings is notice, not always identification)