The Volokh Conspiracy

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Free Speech

Interesting Litigation Pseudonyms


In writing my article on pseudonymous litigation, I've noticed that some pseudonyms aren't mainstays such as Doe or Roe, or deliberately common names such as John Smith, but instead are either puns or references to famous (and perhaps topically connected) works. Three in particular come to mind:

  1. Hester Prynne v. Settle, 848 F. App'x 93 (9th Cir. 2021), where plaintiff was challenging sex offender registry laws (hence the allusion to The Scarlet Letter).
  2. Carol, Marie & Joseph Danvers v. Loudoun County School Bd., No. 1:21-cv-01028-RDA-JFA4 (E.D. Va. Sept. 13, 2021), a sexual assault case in which the high school student plaintiff's pseudonym is the name of Ms. Marvel/Captain Marvel (and the parents' pseudonyms match Ms. Marvel's parents).
  3. Femedeer v. Haun, 227 F.3d 1244, 1246 (10th Cir. 2000), where plaintiff was challenging a sex offender notification law. My guess is that Femedeer is a pun on Doe (a deer, a feme deer).

Are there other examples that belong on the list? (I appreciate that the facts of #2 are fairly grim, and I was surprised to see a seemingly frivolous pseudonym in that case, but I assume that this was something that the plaintiff saw as meaningful and positive.)