B.R. v. F.C.S.B., No. 21-1005 (4th Cir. 2021)
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“Jane Doe,” age 19, filed suit. She alleged in detail multiple acts of sexual harassment and sexual abuse, including rape, against her during several months when she was a student at a Fairfax County, Virginia middle school, and the school’s inaction to end the offensive conduct when it was ongoing. She claimed violations of Title IX of the Education Amendments of 1972 and other laws. She alleged that the defendants undoubtedly knew her identity from the extensive details included in the 40-page complaint. Nonetheless, the defendants filed motions to dismiss, arguing that the plaintiff’s failure to provide her true name had deprived the court of subject-matter jurisdiction and that this jurisdictional flaw could no longer be remedied because the statute of limitations for the federal claims had lapsed days after Doe filed her complaint. The plaintiff then disclosed her true name to the court and requested that she be allowed to proceed under a pseudonym.
The district court denied the defendants’ motions, and, because the sensitive nature of the allegations warranted “the utmost level of privacy,” it allowed the action to proceed pseudonymously. The Fourth Circuit affirmed. While the plaintiff had not adhered to FRCP 10(a), which requires that the title of a complaint include the names of all parties, that failure was immaterial to the court’s subject-matter jurisdiction.
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