P.A. v. St. Tammany Parish School Board et al

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
P.A., individually and on behalf of
minor child A.A. 	CIVIL ACTION
VERSUS 	NUMBER: 26-199
ST. TAMMANY PARISH SCHOOL BOARD, ET AL. 	SECTION: “P” (5)
ORDER AND REASONS
Before the Court is Plaintiffs’ Motion for Leave to Proceed Anonymously Through
Pseudonyms and Plaintiffs’ Ex Parte Motion for Leave to File Exhibit 1 Under Seal. (Rec. docs.
3, 4). Both motions are unopposed. Having reviewed the pleading and the applicable law,
the Court rules as follows.
I. 	Background
P.A., in her individual capacity, and on behalf of her minor child, A.A., filed this action
against the St. Tammany School Board and Superintendent Frank Jabbia on January 28, 2026,
alleging violations of due process rights and federal civil rights under the Individuals with
Disabilities Acts, 20 U.S.C. § 1400 et seq. (2005) (“IDEA”); the IDEA regulations in 34 C.F.R. §
300.30 et seq; Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. § 794 (“Section 504”);
Title II of Americans with Disabilities Act, 42 U.S.C. § 12131, et seq. (“ADA”); and state special
education regulations contained in Louisiana Bulletins 1508, 1530, and 1706. (Rec. doc. 1).
Plaintiffs have asked the Court for permission to proceed anonymously through
pseudonyms to protect their privacy, and particularly, the privacy of child, A.A. (Rec. doc. 3-
1). Plaintiffs argue they are entitled to anonymity because they are raising issues of utmost
sensitivity and challenging government activity. (Id.). Further, they argue that proceeding
anonymously through pseudonyms will not prejudice the Defendants or impair the public’s
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interest in open judicial proceedings. (Id.). Plaintiffs also request that Exhibit 1 be filed under
seal and remain under seal until further order from this Court. (Rec. doc. 4-1). Counsel for
Plaintiffs has filed Exhibit 1, which is a non-anonymized list of the Plaintiffs, under seal so
that the Defendants, but not the public, will know Plaintiffs’ true identities. (Rec. doc. 3-1).
II. 	Law and Analysis
Rule 10(a) of the Federal Rules of Civil Procedure requires that a “complaint must
name all the parties.” “This rule protects the public's legitimate interest in knowing all the
facts involved in the case, including the parties’ identities.” Doe v. Compact Info. Systems, Inc.,
2015 WL 11022761, at *3 (N.D. Tex. Jan. 26, 2015) (citation omitted). “Nonetheless, under
some circumstances a party may proceed anonymously or under a pseudonym.” Doe v.
Griffon Mgmt. LLC, 2014 WL 7040390, at *1 (E.D. La. Dec. 11, 2014). Per the Fifth Circuit,
whether to allow a party to proceed anonymously “requires a balancing of considerations
calling for maintenance of a party's privacy against the customary and constitutionally-
embedded presumption of openness in judicial proceedings.” Doe v. Stegall, 653 F.2d 180,
186 (5th Cir. 1981).
Factors to consider in determining whether anonymity is warranted include whether
the plaintiff seeking anonymity is suing to challenge governmental activity, whether
prosecution of the case will compel plaintiff to disclose information “of the utmost intimacy,”
and whether the plaintiff will be compelled to admit his intention to engage in illegal conduct.
Id. at 185 (citation omitted). Other factors courts have considered include potential threats
of violence, the prejudicial impact on the defendants if the plaintiff is allowed to proceed
anonymously, and fairness to the public. Compact Info. Systems, 2015 WL 11022761, at *3
(citations omitted). The Fifth Circuit has also considered the vulnerability of child-litigants
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as a significant factor in arguing for anonymity. See Stegall, 653 F.2d at 186. “Because none
of the factors are dispositive, but deserve consideration, a Judge should carefully review all
the circumstances of a given case and then decide whether the customary practice of
disclosing the plaintiff's identity should yield to the plaintiff's privacy concerns.” Id. (quoting
Doe v. Frank, 951 F.2d 320, 323 (11th Cir. 1992)) (internal quotations and punctuation
omitted) (emphasis in original). “In the end, the primary concern underlying the relevant
factors is whether the plaintiff likely would suffer real and serious harm if [he] were not
permitted to use a pseudonym.” Doe ex rel. Doe v. Harris, 2014 WL 4207599, at *2 (W.D. La.
Aug. 25, 2014) (citing Victoria W. v. Larpenter, 2001 WL 406334, at *1 (E.D. La. Apr. 17,
2001)).
Applying these factors here, the Court finds that they weigh in favor of allowing
Plaintiff to proceed in this case under a pseudonym. Plaintiffs’ case challenges government
activity by alleging that Defendants, St. Tammany Parish School Board and Frank Jabbia, in
his official capacity as Superintendent of St. Tammany Parish Public Schools, have
discriminated against Plaintiffs on the basis of A.A.’s disability. (Rec. doc. 3-1). Plaintiffs’ suit
also requires the disclosure of intimate details including disability status, financial status,
mental health diagnoses, treatment history, and educational history. (Id.). Plaintiffs allege
they must raise as part of their claims the tangible effect of Defendant’s failures, including
trauma, parenting challenges, and strained family lives. (Id.). This Court has found that cases
involving certain areas should be afforded privacy by allowing pseudonyms. See e.g., Doe v.
AstraZeneca Pharm., LP, 2015 WL 4661814, at *5 (E.D. La. Aug. 5, 2015) (findings that cases
involving abortion, birth control, transsexuality, mental illness, welfare rights of illegitimate
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children, AIDs, and homosexuality are the types of cases that warrant anonymity (internal
citations omitted)).
The Court also recognizes the value of applying sensitivity and flexibility to the special
needs of parents and children. 	Although children generally are protected by the same
constitutional guarantees against governmental deprivations as are adults, the State is
entitled to adjust its legal system to account for children's vulnerability and their needs for
“concern, . . . sympathy, and . . . paternal attention.” Bellotti v. Baird, 443 U.S. 622, 635 (1979)
(citing McKeiver v. Pennsylvania, 403 U.S. 528, 550 (1971) (plurality opinion)). 	Here, the
Plaintiff is a 10-year-old child with autism suing Defendants for various claims including
violating the ADA by denying Plaintiffs meaningful access to education and discriminating
against him on the basis of disability. The privacy stakes are high when the suit is brought
by children and their parents. See Stegall, 653 F.2d at 186.
As other courts have recognized—in IDEA cases, no less—a parent’s identity, “if
disclosed, could jeopardize the child’s confidentiality.” J.W. v. D.C., 318 F.R.D. 196, 199 (D.D.C.
2016) (quoting P.M. v. Evans–Brant Cent. Sch. Dist., 2012 WL 42248, at *3 (W.D.N.Y. Jan. 9,
2012). In IDEA cases, in particular, courts have allowed both parents and children to proceed
anonymously. See, e.g., G.H. v. District of Columbia, 2013 WL 5297203, at *1 n. 1 (D.D.C. Aug.
16, 2013); P.M., 2012 WL 42248, at *3; C.B. v. Pittsford Cent. School Dist., 2009 WL 2991564,
at *4–5 (W.D.N.Y. Sept. 15, 2009). While Federal Rule of Civil Procedure 5.2(a) acknowledges
the privacy interests of minor children by allowing parties to reference minors only by their
initials, it cannot be reasonably suggested that this protection would not be “eviscerated
unless the parent was also permitted to proceed using initials.” C.B., 2009 WL 2991564, at *4
(quoting P.M. v. Evans–Brant Cent. Sch. Dist., 2008 WL 4379490, at *3 (W.D.N.Y. Sept. 22,
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2008)). Accordingly, courts have concluded that parents may proceed anonymously in IDEA
cases to “protect the family and child from further embarrassment and publicity regarding
the child's disability.” Doe v. Alfred, 906 F.Supp. 1092, 1093 n. 1 (S.D.W.Va.995). As such, it
is reasonable to allow P.A. to proceed anonymously, as she is the mother of A.A.
Finally, the Court can find no prejudice to Defendants by allowing Plaintiffs to proceed
anonymously; Defendants know the identity of both the child-litigant and his parent and will
be able to conduct this litigation without impediment. See Doe v. Colgate Univ., 2016 WL
1448829, at *3 (N.D.N.Y. Apr. 12, 2016) (“Furthermore, Defendants are aware of Plaintiff's
true identity and will have an uninhibited opportunity to litigate this matter regardless of
whether Plaintiff's identity is disclosed publicly”).
Plaintiffs, through their attorney, have submitted under seal Exhibit 1, a non-
anonymized list of the Plaintiffs. They have requested that Exhibit 1 be filed under seal to
maintain privacy and anonymity. To ensure compliance with Federal and Local Rules, the
Court ordinarily requires plaintiffs permitted to proceed under pseudonym to file, ex parte
and under seal, “a declaration containing their real names and residential addresses.” Doe v.
Fed. Republic of Germany, 680 F. Supp. 3d 1, 4 (D.D.C. 2023). (quoting Sponsor v. Mayorkas,
No. 23-712, 2023 WL 2598685, at *3 (D.D.C. Mar. 22, 2023). Therefore, it is fully within the
Court’s discretion to allow Plaintiffs to file such documents under seal. E.B. v. Landry, 2020
WL 5775148, at *6 (M.D., La. Sept. 28, 2020).
III. 	Conclusion
Accordingly, and for the foregoing reasons,
IT IS ORDERED that Plaintiffs’ Motion for Leave to Proceed Anonymously Through
Pseudonyms (rec. doc. 3) is GRANTED.
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IT IS FURTHER ORDERED that all parties, their attorneys, and agents shall not
disclose the true identities of the Plaintiffs in the instant litigation, and instead, shall use the
pseudonyms offered by the Plaintiffs.
IT IS FURTHER ORDERED that Plaintiffs Ex Parte Motion for Leave to File Exhibit 1
Under Seal is GRANTED.
New Orleans, Louisiana, this 	day of 	, 2024.
MICHAEL B. NORTH
UNITED STATES MAGISTRATE JUDGE
30th	March
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