No Pseudonymity for Yale MBA Student Suing Over Discipline for Alleged Use of AI on Exam
In the case of Doe v. Yale Univ., Judge Sarah Russell ruled against John Doe, who sued the university over disciplinary action related to the alleged use of AI on an exam. The judge's decision denied the MBA student's request for anonymity in the lawsuit. The ruling highlights the importance of transparency in legal proceedings. The case underscores the potential consequences of academic misconduct. Ultimately, the decision has implications for future cases involving similar issues.
Summary of Judge's Decision in Doe v. Yale Univ.
From today's decision by Judge Sarah Russell (D. Conn.) in Doe v. Yale Univ.: John Doe brought this action after he was suspended from graduate studies at the Yale School of Management ("SOM"). After completing his undergraduate degree at Rice University in 2012, Doe pursued a career as an entrepreneur and investor.
Doe enrolled in 2023 in SOM's Master of Business Administration for Executives (EMBA) program as a member of the class of 2025. In the summer and fall of 2024, SOM convened disciplinary proceedings against Doe after an instructor accused Doe of using generative Artificial Intelligence (AI) during an examination. After various proceedings, SOM found that Doe engaged in academic misconduct; in response, SOM imposed a one-year suspension from campus and a mandatory "F" grade in the class.
Doe asserts in his Complaint that SOM instructors and administrators scrutinized his exam because he is a non-native English speaker {Doe is a French national and a United States resident}, that administrators retaliated against him after he accused them of national origin discrimination, and that SOM disciplined him without regard to the procedural safeguards for students provided by SOM's Honor Code.
Legal Claims and Relief Sought by John Doe
Doe sues Defendants for breach of contract, breach of the implied covenant of good faith and fair dealing, national origin discrimination in violation of Title VI, retaliation in violation of Title VI, intentional infliction of emotional distress, and negligent infliction of emotional distress. Doe seeks money damages as well as declaratory and injunctive relief removing the mandatory "F" grade from his transcript and permitting him to resume studies immediately at SOM.
Ruling on Anonymity
The court doesn't deal with the substantive claims but concludes that Doe can't proceed under a pseudonym. Rule 10 of the Federal Rules of Civil Procedure instructs that "[t]he title of the complaint must name all the parties." This requirement serves the vital purpose of facilitating public scrutiny of judicial proceedings and cannot be set aside lightly. To overcome the presumption of disclosure, a plaintiff must demonstrate that their interest in anonymity outweighs the public interest in identifying the plaintiff.
The judge considered various factors in denying anonymity to John Doe, including the lack of vulnerability compared to typical litigants, the absence of evidence of retaliatory harm from disclosure, and the public interest in disclosure due to the nature of the claims brought against private individuals at a private university.
The judge emphasized that the potential for embarrassment or public humiliation alone does not justify a request for anonymity and highlighted the importance of public access to court proceedings.