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Filing Pseudonymously: Ohio

1. Ohio

   1. Caselaw

      The Ohio Court of Appeals accepts Doe plaintiffs, but no reported cases outline the procedure or test used to determine whether a plaintiff may proceed pseudonymously. The underlying facts of the Lodi Hospital appeal give some indication of the type of fact pattern for which trial courts may grant permission to proceed pseudonymously, and suggests that some defamation or other privacy-based tort plaintiffs may be able to successfully move for use of pseudonym

      • Doe v. Lodi Hospital, No. 2955-M, 2000 WL 1825095 (Ohio Ct. App. 2000) – The court footnotes the fact that the trial court granted the plaintiff permission to maintain the cause of action under a John Doe pseudonym. Doe was a physician and employee of the defendants, a hospital and a regional physician independent contracting company, who claimed defamation, intentional and negligent infliction of emotional distress, wrongful discharge, and intentional interference with contract stemming from a theft at the hospital. Doe’s picture was indicated by one hospital employee as potentially matching a security film of the thief using the stolen credit card at an ATM. The police then questioned more hospital employees familiar with Doe to verify if he was the individual in the security film; however, one such individual was the director of the independent contracting services. Shortly thereafter, Doe was terminated from employment by the hospital and the independent contracting company.

      Ohio has many other reported cases with Doe plaintiffs, but courts have done little beyond note that the name Doe is a pseudonym.

      • Several cases in which Doe plaintiffs bring claims from infection of stigmatizing diseases: Doe v. Hi-Stat Mfg. Co., Inc., 2001 WL 1782657 (Ohio Ct. App. 2001) (Doe, janitor, infected by Hepatitis C while working); Doe v. University of Cincinnati, 538 N.E.2d 419 (Ohio Ct. App. 1989) (Doe infected with HIV from blood transfusion).

      • Doe plaintiff brings claims for unconsented HIV test in Doe v. Ohio State Univ. Hosp. & Clinics, 663 N.E.2d 1369 (Ohio Ct. App. 1995).

      • Cases involving medical conditions or records also have Doe plaintiffs: Doe v. Blue Cross/Blue Shield of Ohio, 607 N.E.2d 492 (Ohio Ct. App. 1992) (minor Doe admitted to hospital for suicide; claim for insurance payment); Stone v. City of Stow, No. 14691, 1991 WL 11365 (Ohio Ct. App. 1991) (Does take drugs for ADD and contest state registry for drug users); Doe v. Mount Carmel Health Systems, No. 03AP-413, 2004 WL 557333 (Ohio Ct. App. 2004) (Doe sues when his visit to hospital from work injury results in doctor revealing he is cross-dresser and not a woman to his employer); Doe v. University Hospitals of Cleveland, No. 61391, 1992 WL 333157 (Ohio Ct. App. 1992) (Doe’s claims arise from his sexual re-assignment surgery).

      • Cases involving sexual abuse of minors. See, e.g., Doe v. Massillon City School Dist., No. 2006CA00227, 2007 WL 1651438 (Ohio Ct. App. 2007) (Doe children molested by chess tutor brought to school); Doe v. Archdiocese of Cincinnati, 849 N.E.2d 268 (Ohio 2006) (Doe sues for sexual abuse by priest dating from when he was a child). But see also Doe v. Blaney, No. C-950093, 1995 WL 763623 (Ohio Ct. App. 1995) (John Doe is minor sexually abused by landlord’s son; all names are revealed in the opinion). And sexual assault of adults. See, e.g., Doe v. Cub Foods of Ohio, Inc., No. 94APE07-1005, 1995 WL 318776 (Ohio Ct. App. 1995) (Doe assaulted in parking lot; assailant steals wallet and learns address and rapes her at home weeks later; Doe then self-mutilates due to post-traumatic disorder).

      • Family law. See, e.g., Doe v. State Board of Health, Not Reported in N.E.2d, 1985 WL 6712 (Ohio Ct. App. 1985) (Doe is a married woman but she and husband want paternity of her newborn recorded as Roe, another man).

   2. Filing Requirements & Availability of Court Records

      OHIO CIV. R. 10 (2010): Form of Pleadings

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

      Ohio opinions are searchable back to 1992 at http://www.court.state.nd.us/Search/Opinions.asp (last visited Apr. 20, 2010).

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