Filing Pseudonymously: North Carolina


  1. North Carolina
  1. North Carolina

    1. Caselaw

      Caselaw from North Carolina does not discuss a rule or even reasons for granting the use of pseudonyms, although several reported cases have Doe plaintiffs.

      • ACT-UP Triangle (AIDS Coalition to Unleash Power Triangle) v. Comm’n for Health, 472 S.E.2d 605 (N.C. Ct. App. 1996) – Doe plaintiffs seek anonymous HIV testing which is being discontinued by state agency. There is no discussion of pseudonyms.

      • Doe v. Duke University, 455 S.E.2d 470 (N.C. Ct. App. 1995) – Doe’s breast implant surgery results in infection requiring removal of implants. She sues, and instant matter relates to custody of the removed implants during the dispute. No discussion of pseudonym.

      • Doe v. Jenkins, 547 S.E.2d 124 (N.C. Ct. App. 2001) – Doe is assaulted and raped in courthouse, and seeks damages from her injuries. No discussion of pseudonym.

      • Roe v. The Childrens School, 576 S.E.2d 142 (N.C. App. 2003) – Doe and Roe are minors sexually abused by employees of Defendant. No discussion of pseudonyms.

    2. Filing Requirements & Availability of Court Records

      N.C. GEN. STAT. § 3-10(a): Form of pleadings

      “ . . . In the complaint the title of the action shall include the names of all the parties . . . .”

      Opinions from appellate courts are available and searchable at, from 1997/96 and forward (last visited Apr. 20, 2010).

    3. Relevant Statutes

      • N.C. GEN. STAT. § 7B-2901 (2010) provides for confidentiality of juvenile court records.

      • N.C. GEN. STAT. § 122C-207 (2010) provides for confidentiality of court proceedings under the Mental Health, Development Disabilities, and Substance Abuse Act of 1985.

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