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Jane Doev.Archdiocese of Atlanta et al.

CourtCourt of Appeals of Georgia
Docket No.A14A0603
DecidedJuly 15, 2014
Reporter328 Ga. App. 324, 761 S.E.2d 864 (2014)
JudgesJudge Dillard authored the opinion; Presiding Judge Doyle and Judge Miller concurred
Tags
CivilCivil ProcedureFamily LawStatutory InterpretationReversalRemand
Case Summary

Doe sued the Atlanta archdiocese and Holy Cross Catholic Church, alleging childhood sexual abuse by a former church employee; she filed under a pseudonym and disclosed her identity to the court under seal. The trial court dismissed the complaint as a legal nullity after the limitations period had expired. The Court of Appeals held that the complaint was not a nullity because Doe was a real person and had timely disclosed her identity to the Church and the court. It left to the trial court the fact-specific decision whether Doe could continue using a pseudonym, directing the court to balance privacy interests against public access and the defendants’ interests. The court explained that the Civil Practice Act favors amendment and substantial justice, while anonymous litigation requires a careful, discretionary assessment. It reversed and remanded for the trial court to decide whether Doe could proceed under a pseudonym under the stated factors.

Opinion

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