Filing Pseudonymously: Idaho
Idaho has tacitly accepted Doe pseudonyms for privacy tort claims cases in one reported, but unpublished, case.
- Doe v. Haw, No. CV OC 0205441D, 2003 WL 21015134 (Idaho, 2003) (not Reported in P.3d) – Doe had health and psychiatric issues resulting in an unnecessary hospitalization; she is treated by Defendant, a doctor, and he pays to publish a diatribe in local newspaper (also Defendant), against local medical board, reproducing in it a confidential letter he requested Doe write to medical board on his behalf, without her permission. Her name is reproduced in the newspaper. Doe sues for invasion of privacy, inter alia. The court does not address the use of the pseudonym.
Other reported Doe cases are much less analogous, such as civil suits stemming from sexual assault of minors (Roe v. Albertson's Inc., 112 P.3d 812 (Idaho 2005); Doe v. Sisters of Holy Cross, 895 P.2d 1229 (Idaho Ct. App., 1995)), or parental rights cases (Roe Family Services v. Doe, 139 Idaho 930, 88 P.3d 749 (Idaho, 2004)).
Filing Requirements & Availability of Court Records
IDAHO R. CIV. PRO. 10(a)(1) (2010): Form of pleadings – Caption – Name of parties
Every pleading, motion, notice, or judgment or order of the court shall . . . contain a caption setting forth the names of the parties . . . . In the complaint the title of the action shall include the names of all of the parties . . . .
Idaho Supreme Court Opinions and appellate court opinions back to 2006 are available the Idaho State Judiciary website (last visited Apr. 10, 2010).
IDAHO CODE ANN. RULE 32 (2010): Records of the judicial department -- Examination and copying -- Exemption from and limitations on disclosure.
This statute provides for confidentiality of certain types of information in court records. In some cases, courts can allow pseudonymity to provide this confidentiality. See § (h): Permissive Release of Judicial Decision in Exempted Categories.