ROBINSON v. TRULIEVE INC
4:24-cv-00391
N.D. Fla.Dec 19, 2024Background
- Plaintiff, using the pseudonym John Doe, sued Trulieve Inc. after alleging the company improperly disclosed his online marijuana purchases.
- Legal claims included common law invasion of privacy, breach of contract, violation of Florida’s unfair trade practices law, and violation of the federal Electronic Communications Privacy Act.
- Plaintiff requested to proceed anonymously, arguing stigma and potential professional harm from public disclosure of his marijuana use.
- The court previously emphasized the strong presumption that parties in civil litigation proceed in their real names.
- Trulieve moved to dismiss, but that motion became moot due to the plaintiff's anonymity request.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proceed anonymously | Plaintiff argues marijuana use is highly stigmatized and disclosure would harm his reputation and employment, particularly as a medical professional. | Emphasizes presumption of openness in judicial proceedings and lack of specific, substantiated harm to plaintiff. | Motion to file anonymously denied; plaintiff must proceed under real name. |
Key Cases Cited
- In re Chiquita Brands Int’l, Inc., 965 F.3d 1238 (11th Cir. 2020) (sets out factors when anonymity may be justified, emphasizing its rare application)
- Doe v. Frank, 951 F.2d 320 (11th Cir. 1992) (upholds presumption of openness and describes limited circumstances for anonymity)
- Plaintiff B v. Francis, 631 F.3d 1310 (11th Cir. 2011) (further discusses standards and exceptions for anonymity)
- S. Methodist Univ. Ass’n of Women Law Students v. Wynne & Jaffe, 599 F.2d 707 (5th Cir. 1979) (fairness requires accusers suing publicly to proceed under their real names)
