Filing Under a Pseudonym
Oregon courts have not directly addressed a test or reasons for Doe pseudonyms. The facts of reported cases with Doe plaintiffs may be helpful in drawing analogies to the privacy interests that support pseudonymity.
- Doe v. American Red Cross, 910 P.2d 364 (Or. 1996) – Doe’s estate sues for the negligence in the transmission of HIV to Doe during a blood transfusion, the lack of testing and warning of risks of transfusions. Doe died of AIDS. No mention of pseudonym.
- Doe v. Medford School Dist., 221 P.3d 787(Or. Ct. App. 2009) – Teacher, Doe, challenged school board ordinance that forbade guns in schools, as the licensed teacher wanted to carry handgun to class and while teaching. No mention of pseudonym.
- Doe v. Portland Health Centers, Inc., 782 P.2d 446 (Or. Ct. App. 1989) – The minor daughter of Does attempts suicide and hospital workers treating her leak the information to others in the community. Mother Doe is medical professional who seeks reputational damages to her practice. No mention of pseudonym.
- Doe v. Oregon Conference of Seventh-Day Adventists, 111 P.3d 791 (Or. Ct. App. 2005) – Doe, a minor, is touched by her pastor’s minor son in sexual manner and brings negligent supervision claim. No mention of pseudonym.
Filing Requirements & Availability of Court Records
OR. R. CIV. PRO. 16 (2009): Captions, Names of parties:
“. . . In the complaint the title of the action shall include the names of all the parties . . . .”
Court of appeals opinions are available dating back to 1998 at http://www.publications.ojd.state.or.us/appeals.htm (last visited Apr. 20, 2010).
OR. REV. STAT. § 192.420 (2009) states a right to inspect public records.