Filing Pseudonymously: Utah


  1. Utah
  1. Utah

    1. Caselaw

      Caselaw from Utah does not treat a test for pseudonymity. Several cases do tacitly allow adult plaintiffs to proceed pseudonymously, even at the state Supreme Court, with the claims generally involving the revelation of medical records or conditions:

      • Doe v. Hafen, 772 P.2d 456 (Utah App. 1989) – Doe brings claims from a motorcycle collision, arguing she sustained head injuries leading to mental problems. Defendant argues these problems are from depression stemming from Doe’s prior miscarriage and voluntary sterilization, and wants to raise these issues in trial. No mention of pseudonym.

      • Doe v. Maret, 984 P.2d 980 (Utah 1999) – Doe sues for medical malpractice when her mental health records are improperly disclosed to her husband’s attorney during previous divorce proceedings which resulted in grant of custody of children to the husband. No discussion of pseudonym.

      Most reported caselaw from Utah courts with Doe plaintiffs, however, involves sexual abuse of minors and contains no discussion of the use of the pseudonym:

      • Doe v. Corp. of President of Church of Jesus Christ of Latter-day Saints, 98 P.3d 429 (Utah App. 2004) – John Doe, a minor, was sexually abused by LDS priest.

      • Savage v. Utah Youth Village, 104 P.3d 1242 (Utah 2004) – Doe family sues due to foster child placed in their home who molested their son.

      • Doe v. Doe, 878 P.2d 1161 (Utah App. 1994) – Doe parents sue defendant Doe parents for negligent supervision when Defendant’s boy tries to have sex with Plaintiffs’ 8 year old daughter.

      • Doe v. Arguelles, 716 P.2d 279 (Utah 1985) – Custodian of minor girl sues when she is stabbed and raped by a minor on release from juvenile detention.

    2. Filing Requirements & Availability of Court Records

      URCP Rule 10 (2010): Form of Pleadings and Other Papers

      “(a) (2) In the complaint, the title of the action shall include the names of all the parties . . . .”

      Searchable Supreme Court and courts of appeal unpublished and published opinions available at (last visited Apr. 20, 2010).

    3. Relevant Statutes

      None noted.

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