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U Michigan Student Sues Alleging Wrongful Discipline for Unauthorized AI Use—But Can't Sue as a Jane Doe
From Doe v. Regents of Univ. of Mich., decided yesterday by Judge Laurie Michelson (E.D. Mich.):
Plaintiff, a student at the University of Michigan, was disciplined her for alleged academic misconduct—an unauthorized use of AI to write course papers. She was put on disciplinary probation and required to write a 1,000-word reflective essay. Plaintiff maintains that she has "documented disabilities" including generalized anxiety disorder and obsessive-compulsive disorder. She alleges that her "disability-related writing traits could be misinterpreted as AI and should not be treated as proof of misconduct." Thus, on February 9, 2026, she filed this lawsuit against numerous University of Michigan officials and instructors, claiming that the disciplinary action violated the Rehabilitation Act, the Americans with Disabilities Act, and her procedural due process rights….
Doe sought leave to proceed under a pseudonym (as people suing pseudonymously generally must do), but the court said no. The court rejected her claim that pseudonymity was justified by risk of reputational harm claim:
Plaintiff's contention that she would suffer "a severe stigmatic and reputational injury" if she had to litigate under her name is unsupported. Plaintiff says that "harm cannot be fully cured by later relief" if her identity tied to "alleged academic dishonesty and to mental health information[,]" is disclosed." But "[u]nsubstantiated fears of speculative harm are insufficient to outweigh the presumption of open judicial proceedings."
[And] Plaintiff's argument that "claims of academic dishonesty" would impact her "ability to practice professionally as a physician" is not a legally cognizable consideration under Porter. See Doe v. Univ. of Akron(collecting cases where courts denied requests by plaintiffs faced with academic dishonesty allegations who claim "damage to [their] reputation" and concerns about "career opportunities")….
The Court appreciates Plaintiff's situation. But many federal court plaintiffs must face disclosure of sensitive or personal information that they would likely prefer to keep private. Plaintiff fails to carry her burden to show that her case is otherwise exceptional.
The court also reasoned that the claim didn't involve matters of "utmost intimacy":
Plaintiff believes that "utmost intimacy" includes her "mental health conditions, treatment, and disability-related accommodations." But she does not provide any authority to support that these types of concerns constitute "utmost intimacy" under Porter [the Sixth Circuit precedent] and there is substantial case law to support that they are not. See Doe v. Bowling Green State Univ. (N.D. Ohio 2022) (explaining that most "college students challenging disciplinary procedures are required to proceed in their own name") (collecting cases); Doe v. Univ. of Akron (N.D. Ohio 2016) (reasoning that "plaintiff's interest in maintaining the privacy of her medical information and alleged disabilities" can be remedied by a protective order, not a pseudonym, and finding that "none of the medical conditions identified by plaintiff in her complaint—ADHD, anxiety, depression" involve matters of the 'utmost intimacy'"). This intuitively makes sense as there is no shortage of disability discrimination litigation pursued in the plaintiffs' own names….
The case Plaintiff relies on, Doe v. Streeter (E.D. Mich. 2020), involved an unopposed motion to proceed under a pseudonym where the claim involved sexual abuse and child pornography. Indeed, "[c]ourts have recognized sexual assault victims as paradigmatic examples of persons who ought to be entitled to grants of anonymity." By contrast, the opposed motion here concerns accommodation for a student's not uncommon mental health issues. This is not to minimize them. But the factual allegations here simply do not implicate the privacy concerns in the case Plaintiff relies on. See Doe v. Univ. of Detroit Mercy Sch. of Dentistry (E.D. Mich. 2025) ("The underlying misconduct at issue here details Plaintiff sending risqué and controversial text messages and website links, asking students on dates, being labeled a 'stalker,' seeking treatment and experiencing side effects from his ADHD medication, and being dismissed from the University as a result. While these are personal and serious matters to Plaintiff, they are insufficient to reach the high burden of the 'utmost intimacy' that outweighs the public's interest in open judicial proceedings.").
Brian M. Schwartz and Conrad R. Wolan (Miller, Canfield, Paddock and Stone, P.L.C.) represent defendants. Charles Blackwell also moved to intervene on his own behalf to oppose pseudonymity, but given that the pseudonymity motion was denied, the court denied Blackwell's motion as moot.
