Filing Pseudonymously: Vermont


  1. Vermont
  1. Vermont

    1. Caselaw

      Reported Doe cases brought by civil plaintiffs in Vermont courts are limited to those with claims stemming from unlawful sexual relations. The opinions do not treat the use of pseudonyms, but the facts may be somewhat helpful for analogy for future plaintiffs wishing to proceed pseudonymously.

      • Doe v. Forrest, 853 A.2d 48 (Vt. 2004) – Doe is coerced into sex with the Deputy Sheriff after his repeated visits to her workplace, a store, and sexual innuendo. There was a criminal conviction prior to the civil suit. No discussion of pseudonymity.

      • Doe v. Newbury Bible Church, 182 Vt. 174, 933 A.2d 196 (Vt. 2007) – Doe is a minor abused by a pastor of the church. No discussion of the pseudonym.

    2. Filing Requirements & Availability of Court Records

      V.R.C.P. Rule 10 (2009): Form of Pleadings

      “(a) Caption; Names of Parties . . . In the complaint, the title of the action shall include the names of all the parties . . . .”

      Vermont only provides for free the opinions of recent Superior Court decisions, at (last visited Apr. 20, 2010).

    3. Relevant Statutes

      • VER. STAT. ANN. tit. 15A § 6-102 (2010) seals records of adoptions.

      • VER. STAT. ANN. tit. 12 § 1705 (2010) provides for limited use of pseudonyms for proceedings regarding individuals infected with HIV.

      • VT. PUB. ACC. CT. REC. Rule 6 (2009) provides for a general right of public access to court records, with several exceptions, including juvenile and mental health proceedings, and financial information.

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