Filing Pseudonymously: Minnesota


  1. Minnesota
  1. Minnesota

    1. Caselaw

      Minnesota caselaw does not treat the issue of filing pseudonymously directly, but cases tacitly allow pseudonym in relation to claims of confidential records.

      • Doe v. Anoka County Bd. of Com'rs, No. C8-92-544, 1992 WL 238373 (Minn. Ct. App. 1992) – Doe challenges the unsealing of a “pardon extraordinary” of his felony conviction, but there is no discussion of the use of a pseudonym.

      • Doe v. Minnesota State Bd. of Medical Examiners, 435 N.W.2d 45 (Minn. 1989) – Dr. Doe sued to prevent Board from disclosing complaints against him which were dismissed in the Board’s final ruling, which is to be a public record. No discussion of pseudonym.

      • Resident v. Noot, 305 N.W.2d 311 (Minn. 1981) – Pseudonymous elder care facility resident sues to keep medical assistance funding. Court merely mentions pseudonym.

      Most other reported cases with Doe plaintiffs include underlying claims relating to sexual assault or harassment. Furthermore, several are founded on events stemming from when plaintiffs were minors. The facts are somewhat extreme, and would be hard for a privacy-based plaintiff who did not suffer additional harms to analogize to.

      • Doe v. Archidocese of St. Paul and Minneapolis, No. C5-03-11896, 2005 WL 517772 (Minn. Dist. Ct. 2005) – Doe is Defendant’s employee, married, who has inappropriate relationship with a priest but does not actually have sex with him, and brings claims of battery and harassment, inter alia. No discussion of pseudonym.

      • Doe v. Brainerd Intern. Raceway, Inc., 533 N.W.2d 617 (Minn. 1995) – Doe is teenage girl who sneaks into race day celebrations and participates in wet t-shirt contest which devolves into nudity and sex acts in front of crowd while she is drunk and high. Negligence claims; no discussion of pseudonym.

      • Quenroe v. Order of St. Benedict of Roman Catholic Church, No. A03-1212, 2004 WL 1381195 (Minn. Ct. App. 2004) – Doe plaintiff claims sexual abuse by priest ten years previously when a minor. No discussion of pseudonym.

    2. Filing Requirements & Availability of Court Records

      MINN. R. CIV. P. 10.01 (2010): Caption – Names of Parties

      “ . . . In the complaint, the title of the action shall include the names of all the parties, but in other pleadings it is sufficient to state the first party on each side with an appropriate indication of other parties.”

      Recent Supreme Court opinions are available at, while all archived Supreme Court and appellate opinions are searchable at (last visited Apr. 20, 2010).

    3. Relevant Statutes

      • MINN. STAT. § 145.4247 provides for pseudonymity of a woman proceeding in court for violations of the Woman’s Right to Know Act (relating to abortions).

      • MINN. R. JUV. PROT. P. 8.04 (2010) states what records are not available to the public, including those from juvenile court proceedings, relating to HIV, etc.

      • MINN. R. PUB. ACCESS REC'DS JUD. BR. 8 (2010) provides for public access to records.

      • MINN. R. CIV. APP. P. 112.01 (2010) relates to sealing the record.

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