Doe v. Yale Univ.

── Doe v. Yale Univ. ── Court: Court of Appeals for the Second Circuit Date: April 20, 2026 Category: General 25-1564-cv (L) Doe v. Yale Univ. et al. UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL. At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 20th day of April, two thousand twenty-six. PRESENT: DENNIS JACOBS, RICHARD C. WESLEY, MICHAEL H. PARK, Circuit Judges. __________________________________________ JANE DOE, Plaintiff-Appellant, v. 25-1564 (Lead), 25-1712 (Con) YALE UNIVERSITY, GORDON SILVERSTEIN, KIMBERLY MCKEOWN, Defendants-Appellees. __________________________________________  FOR PLAINTIFF-APPELLANT ALEXANDER T. TAUBES, Law Offices of Alexander T. Taubes, PLLC, New Haven, CT. FOR DEFENDANTS-APPELLEES PATRICK M. NOONAN, Giovanna Tiberii Weller, and Jeffrey M. Beck, Carmody Torrance Sandak & Hennessey LLP, Guilford, CT. Appeal from a memorandum and order of the United States District Court for the District of Connecticut (Williams, J.). UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the judgment of the district court is AFFIRMED. Plaintiff Jane Doe appeals from an order of the district court denying her motion to proceed by pseudonym as well as the district court’s order denying reconsideration. Doe, a student in Yale Law School’s Doctor of Juridical Science (“J.S.D.”) program, sued Yale University, Director of Student Accessibility Services Kimberly McKeown, and Assistant Dean for Graduate Programs Gordon Silverstein (collectively, “Yale”), alleging discrimination and retaliation in violation of the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12101 et seq., and Section 504 of the Rehabilitation Act, 29 U.S.C. § 794, as well as breach of contract. Doe primarily claimed that Yale improperly refused to extend her J.S.D. candidacy for an additional year—which she believes she needs in order to produce a dissertation of sufficient quality—and sought injunctive relief barring Yale from discharging her from the program. 2  The same day that she filed her complaint, Doe moved for an order permitting her to proceed by pseudonym. She asserted that her identification as plaintiff in this lawsuit would diminish her academic and employment opportunities because the case would necessarily disclose details concerning her diagnosed medical conditions, her medical treatment history, and the impact of her conditions on her academic performance. She also contended that “[p]ublic disclosure of [her] identity would likely exacerbate her existing psychiatric conditions” and subject her to “stigma associated with mental health conditions.” Dkt.