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Doe v. Archdiocese of Atlanta

The trial court erred in concluding that the plaintiff's complaint was a legal nullity because she filed it using a pseudonym.

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Jane Doe appeals from the trial court’s dismissal of her lawsuit against the Archdiocese of Atlanta and Holy Cross Catholic Church collectively, “the Church”, on the ground that the suit, filed using a pseudonym, was a legal nullity. Because we hold that the trial court erred in concluding that the complaint was void, we reverse. We further hold that the trial court has the discretion to consider whether Doe is entitled to proceed under a pseudonym and, therefore, remand the case for consideration of that issue in a manner consistent with this opinion.

The undisputed facts are as follows. On September 4, 2012, Doe filed a complaint against the Church using the pseudonym “Jane Doe” and alleged that she, now the age of majority, had been the victim of childhood sexual abuse from a former Church employee. Three days later, Doe’s counsel sent the Church a copy of the complaint with a letter revealing Doe’s identity and explaining that, “given the sensitive nature of the allegations,” the complaint had been filed under a pseudonym in order “to protect the identity and avoid future injury to Doe” and asking the Church to advise if it objected to her doing so.1 And then on September 14, 2012, Doe filed a “notice of disclosure of identity of plaintiff Jane Doe,” in which she identified herself under seal to the trial court. Each of the foregoing actions transpired prior to the expiration of the statute of limitations on Doe’s claims.2

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