When Anonymity Isn’t Automatic—Even in Sensitive Health Data Claims

In civil litigation, we often see initials used for minors, and “John Doe” when a party’s identity is truly unknown. I currently represent a minor plaintiff whose name is abbreviated in the pleadings, and I represent K-State Athletics in a case filed against “John Doe,” the unknown person inside a mascot costume.

But what if a fully identified adult wants to remain anonymous—just to avoid embarrassment?

That was the question in Doe v. University of Kansas Hospital Authority, No. 2:25-cv-02200-HLT-TJJ (D. Kan. June 9, 2025), where adult plaintiffs sued over unauthorized access to their medical records and photographs. They filed under pseudonyms, but the court said no.

Judge Holly Teeter ruled this was not an “exceptional case” justifying pseudonymity under the Tenth Circuit standard.
She emphasized that:

• Claims involving sensitive medical info are not rare enough to warrant exception
• The accessed data was past harm, not future threat
• Embarrassment alone isn’t enough to override the presumption of openness
• Even partial anonymity (e.g., using initials) was denied

Takeaway: In Kansas federal court, pseudonymity is a narrow exception—not available just because medical or emo-
tional issues are involved. If you’re filing suit as an adult, prepare for your name to be part of the public record.