Doe v. Archdiocese of N.Y.
2025 NY Slip Op 50338(U)
N.Y. Sup. Ct., New York Cty.2025Background
- John Doe, plaintiff, filed a lawsuit against the Archdiocese of New York and The Church of St. John the Evangelist alleging sexual assault and claiming significant injuries.
- The plaintiff's claims are brought under the Victims of Gender-Motivated Violence Protection Law (GMVA), which revives previously time-barred claims.
- Plaintiff moved to proceed anonymously (using a pseudonym) to avoid stigma related to the nature of the allegations.
- Defendants were properly served but did not oppose the plaintiff's motion for anonymity.
- The court considered the balancing of plaintiff’s privacy interests against the principles of open court proceedings.
- No request was made to seal the records, only to permit anonymity for the plaintiff throughout the action.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiff may proceed anonymously | Disclosure of identity may subject plaintiff to stigma and deter pursuit of such claims | Defendants did not oppose the motion | Plaintiff is granted leave to proceed anonymously |
| Whether anonymity would prejudice the defendants or contravene the public interest in open proceedings | Anonymity is a minimal limitation compared to sealing records and encourages pursuit of meritorious claims under GMVA | No argument presented | Defendants are not prejudiced; public interest in merits outweighs interest in identity |
Key Cases Cited
- Anonymous v. Lerner, 124 A.D.3d 487 (N.Y. App. Div. 2015) (court must balance privacy interests against presumption of openness in trials)
- Doe v. Yeshiva Univ., 195 A.D.3d 565 (N.Y. App. Div. 2021) (anonymity permitted when justified by sensitive subject matter)
- Cole v. Mandell Food Stores, Inc., 93 N.Y.2d 34 (N.Y. 1999) (the purpose of pleadings does not extend to requiring use of plaintiff’s real name)
- Danco Labs. v. Chemical Works of Gedeon Richter, 274 A.D.2d 1 (N.Y. App. Div. 2000) (open judicial process encourages fairness and reduces the risk of injustice)