Although Roe v. Wade may be the most famous case caption in history, there are relatively few cases discussing whether and when a plaintiff has the right to sue anonymously, as a “Jane Roe” or a “John Doe.”

When a federal judge in Philadelphia was faced with a dispute recently over whether the plaintiff should be allowed to proceed under a pseudonym, he found that the 3rd U.S. Circuit Court of Appeals has never addressed the standards for granting anonymity, but that other courts have articulated lists of factors to be weighed.

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