775 F.Supp.3d 1032
D.N.D.2025Background
- Plaintiff filed a complaint against Vitamin Cottage Natural Food Markets Inc. (owner of Natural Grocers), alleging injury from consuming mercury-contaminated seafood sold without sufficient warning or labeling.
- Plaintiff requested to file the complaint under seal and proceed under a pseudonym due to privacy concerns related to personal medical issues, and potential employment discrimination or harassment.
- Plaintiff attached both sealed and redacted versions of the complaint to his motion.
- Plaintiff alleged claims for negligence, negligent infliction of emotional distress, and breach of implied warranty of merchantability.
- The court addressed whether plaintiff's desire for anonymity or confidentiality warranted an exception to the presumption of open judicial proceedings and full disclosure of party names.
- The court analyzed both the plaintiff's request for pseudonymity and the sealing of medical records, considering existing Eighth Circuit and other federal case law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proceeding under a pseudonym | Disclosure of health and disability information is sensitive and could cause retaliation | Not specified | Denied; court found the claims do not meet factors for anonymity |
| Sealing medical records | Plaintiff sought to protect private medical information | Not specified | Granted; medical records to be sealed as confidentiality alternative |
| Public filing of the complaint | Plaintiff argued for sealing/redaction | Not specified | Redacted complaint to be publicly filed; exhibit D sealed, others public |
| Defendant handling of medical records | Requested additional confidentiality protections | Not specified | Defendant ordered not to disclose plaintiff's medical records except to counsel |
Key Cases Cited
- Doe v. Mass. Inst. of Tech., 46 F.4th 61 (1st Cir. 2022) (strong presumption against use of pseudonyms under F.R.C.P. 10(a), 17(a))
- S. Methodist Univ. Ass’n of Women L. Students v. Wynne & Jaffe, 599 F.2d 707 (5th Cir. 1979) (cases about birth control, abortion, other highly personal issues warrant some anonymity)
- Doe v. Blue Cross & Blue Shield United of Wis., 112 F.3d 869 (7th Cir. 1997) (mere presence of medical issues is not sufficient to allow use of a pseudonym)