Filing Pseudonymously: North Dakota


  1. North Dakota
  1. North Dakota

    1. Caselaw

      North Dakota courts have not stated a rule for assessing proceeding under a pseudonym, and cases in which Doe plaintiffs are tacitly allowed are sparse, offering little for analogies.

      • Fargo Women's Health Organization, Inc. v. Larson, 381 N.W.2d 176 (N.D. 1986) – Doe plaintiff is one of several plaintiffs suing an anti-abortion counseling center for false advertising about their abortion/pregnancy counseling services. No discussion of Doe’s identity or use of pseudonym.

      • Roe v. Rothe-Seeger, 608 N.W.2d 289 (N.D. 2000) – Dr. Roe petitions for vacatur of grant of insurance company to intervene in Jane Doe’s medical malpractice claim against him, involving sexual relationship between Roe and Doe. The Court does not discuss the pseudonyms.

    2. Filing Requirements & Availability of Court Records

      N.D.R. CIV. P. R. 10 (2010): Caption – Name of parties

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

      Supreme Court opinions are searchable at (last visited Apr. 20, 2010).

    3. Relevant Statutes

      • N.D.R. CT. RULE 3.4 (2010) provides for protection of PII in court records.

      • N.D. SUP. CT. ADMIN. RULE 41 (2010) sets out a right of public access to court records generally, with exceptions for narrow categories of materials appearing in the record.

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