P.A.

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 EPxla Pinartitfefs’ Motion for Leave to Proceed Anonymously Through

Pseudonyms and Plaintiffs’ 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,

tIh. e CouBrta cruklgerso ausn fdollows.

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 processe rt isgehqt.s and federal civil rights under the Individuals with

Disabilietite sse Aqcts, 20 U.S.C. § 1400 (2005) (“IDEA”); the IDEA regulations in 34 C.F.R. §

300.30 ; Section 504 of the Rehabilitation Act of 1973,e 2t 9se Uq.S.C. § 794 (“Section 504”);

Title II of Americans with Disabilities Act, 42 U.S.C. § 12131, . (“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 Ibde.cause they are raising issues of utmost

sensitivity and challenging government activity. ( ). Further, they argue that proceeding

anonymously through pseudonyms will not prejudice the Defendants or impair the public’s

Id.

interest in open judicial proceedings. ( ). 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

tIhI.a t theL Dawef eanndda Antnsa, blyusti snot the public, will know Plaintiffs’ true identities. (Rec. doc. 3-1).

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 legitDimoaet ve. Cinotmerpeasctt i Inn kfon. oSwysitnegm asl,l I tnhce.

facts involved in the case, including the parties’ identities.” ,

2015 WL 11022761, at *3 (N.D. Tex. Jan. 26, 2015) (citation omitted). “Nonetheless, Duoned evr.

sGormiffeo nc iMrcgummts. tLaLnCces a party may proceed anonymously or under a pseudonym.”

, 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 custDomoea rvy. Satnegda cllonstitutionally-

embedded presumption of openness in judicial proceedings.” , 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,”

aIdn.d whether the plaintiff will be compelled to admit his intention to engage in illegal conduct.

at 185 (citation omitted). Other factors courts have considered include potential threats

of violence, the prejudicial impact on theC doemfepnadcta nIntsfo i.f Styhsete pmlasintiff is allowed to proceed

anonymously, and fairness to the public. , 2015 WL 11022761, at *3

(citations omitted). The Fifth Circuit has also considered the vulnerability of child-litigants

See Stegall

as a significant factor in arguing for anonymity. , 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 Ipdr.actice of

Ddiosec lov.s iFnrga tnhke plaintiff's identity should yield to the plaintiff's privacy concerns.” (quoting

, 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 liDkoeely e xw roeul.l dD oseu fvf.e Hr arrerails and serious harm if [he] were not

permitted to use a pseuVdiocntoyrmia. ”W . v. Larpenter , 2014 WL 4207599, at *2 (W.D. La.

Aug. 25, 2014) (citing , 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 staItdu.s, financial status,

mental health diagnoses, treatment history, and educational history. ( ). Plaintiffs allege

they must raise as part of their claims the tangible effecItd .of Defendant’s failures, including

trauma, parenting challenges, and strained family lives. ( ). This Court has fouSened et.hga.,t D coaese vs.

iAnsvtroalvZiennge ccaer Ptahianr mar.e, LaPs should be afforded privacy by allowing pseudonyms.

, 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

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 chiBldelrleontt'is vv. uBlanierrdability and their needs for

“concerMn,c .K . e. isvyemr pv.a tPheyn,n asnydlv .a .n . ipaaternal attention.” , 443 U.S. 622, 635 (1979)

(citing , 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 disSaebei lSittye.g aTlhle privacy stakes are high when the suit is brought

by children and their parents. , 653 F.2d at 186.

As other courts have recognized—in IDEA caJs.Wes., vn. oD .Cless—a parent’s identity, “if

disclosed, could Pje.Mop. avr. dEivzaen tsh–eB crhainldt ’sC ecnotn. fSidchen. Dtiiasltity.” ., 318 F.R.D. 196, 199 (D.D.C.

2016) (quoting ., 2012 WL 42248, at *3 (W.D.N.Y. Jan. 9,

2012). In IDEAS ceaes, ees.g, i.,n G p.Har. tvi.c Duliastrr, iccot uorft Cs ohlauvmeb ailalowed both parents and children to proceed

anonymousPl.yM. . .B. v. Pitts, f2o0rd1 3C eWntL. S5c2h9o7o2l 0D3is, tat *1 n. 1 (D.D.C. Aug.

16, 2013); , 2012 WL 42248, at *3; C ., 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 protectionC .Bw.ould not be “eviscerated

unless the p.Mar. evn. tE wvaanss a–lBsora pnetr mCeinttte. dS ctoh .p Droiscte.ed using initials.” , 2009 WL 2991564, at *4

(quoting P , 2008 WL 4379490, at *3 (W.D.N.Y. Sept. 22,

2008)). Accordingly, courts have concluded that parents may proceed anonymously in IDEA

cases to “protect the faDmoeil yv . aAnldfr ecdhild from further embarrassment and publicity regarding

the child's disability.” , 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 cSheiled -Dlioteig avn. Ct oanlgda hteis U pnairvent and will

be able to conduct this litigation without impediment. ., 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 Dpoaer tve.

aFnedd. uRnedpeurb lsieca ol,f “Gae dremcalanryation containing their real names and residentSiaplo andsdorre vs.s Mesa.”y orkas

, 680 F. Supp. 3d 1, 4 (D.D.C. 2023). (quoting ,

No. 23-712, 2023 WL 2598685, at *3 (D.D.C. Mar. 22, 2023). Therefore, iEt. Bis. fvu. lLlya nwdirtyhin the

Court’s discretion to allow Plaintiffs to file such documents under seal. , 2020

WIIIL. 577C5o1n4c8lu, asti o*6n (M.D., La. Sept. 28, 2020).

AITc cIoSr OdiRnDglEyR, aEnDd for the foregoing reasons,

thatG PRlaAiNntTifEfsD’ .M otion for Leave to Proceed Anonymously Through

Pseudonyms (rec. doc. 3) is

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

pseudoInTy mISs F oUffReTreHdE bRy OthReD PElaRiEnDtiffs. Ex Parte

GRANTED. that Plaintiffs Motion for Leave to File Exhibit 1

Under Seal is 30th March

New Orleans, Louisiana, this day of , 2024.

MICHAEL B. NORTH

UNIT ED ST ATES M AGIST RATE JUDGE