L.B. and E.G. v. Pittsburgh Public School District
Opinion
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA L.B. and E.G., ) Plaintiff v. ) Civil No. 26-1470 PITTSBURGH PUBLIC SCHOOL ) DISTRICT ) Defendant. Memorandum Opinion and Order Plaintiffs, L.B. and E.G., commenced this pro se action by filing a Complaint and Motion to Proceed Under Initials and Use a Mailing Address Other than Their Home Address. ECF Nos. 1 & 2. Plaintiffs sues the Pittsburgh Public School District pursuant to 20 U.S.C. § 1415@)(2)(A) of the Individuals with Disabilities Education Act IDEA), seeking review of a Pennsylvania Special Education Hearing Officer’s Final Decision and Order with respect to a reevaluation of the minor child Plaintiff's special education needs and services. Decisions regarding whether to allow a party to proceed under a pseudonym are consigned to the sound discretion of the trial court and will not be disturbed absent an abuse of that discretion. Doe v. Megless, 654 F.3d 404, 407 (3d Cir. 2011). In determining Plaintiffs’ Motion, the Court considers the non-exhaustive factors, relevant to the circumstances of the case before the Court, set forth by the Third Circuit in Megless. Id. 409. Here, the identities of the Plaintiffs have been kept confidential because the administrative process, and related events, at issue concerned a minor and thus were not public. In addition, implementation of the minor Plaintiffs special education and related services, by its nature, includes the minor’s sensitive, private educational, behavioral, and medical information. Revealing the minor’s name may jeopardize the confidentiality of such information, which in turn may affect appropriate implementation of services. In addition, the record of this case, except for any properly identified
sealed or redacted information, will be publicly available. Further, the close familial relationship between the minor Plaintiff and the adult Plaintiff compels the conclusion that the adult Plaintiff must also be permitted to proceed with this action using initials. JW. v. D.C., 318 F.R.D. 196, 199 (D.D.C. 2016) (noting that “courts have concluded that parents may proceed anonymously in IDEA cases to ‘protect the family and child from further embarrassment and publicity regarding the child's disability’”) (quoting Doe v. Alfred, 906 F.Supp. 1092, 1093 n, 1 (S.D.W.Va. 1995)). The Court finds that the factors weigh in favor of permitting Plaintiffs to proceed using initials and to use an address other than a home address.
Accordingly, the following Order is entered. And now, this 22nd day of July 2026, it is hereby ORDERED that Plaintiffs’ Motion to Proceed Under Initials and Use a Mailing Address Other than Their Home Address, ECF No. 2, is GRANTED.
IT IS FURTHER ORDERED that Plaintiffs may proceed in this action under the initials, L.B. and E.G., and that the public docket and public filings shall identify Plaintiffs using those initials L.B. and E.G. Any public filing that contains either of Plaintiffs’ names and/or other identifying details shall be redacted before filing on the public record. Defendant shall confer with Plaintiffs regarding any confidential or personal private information contained in a planned filing that Defendant believes need not be redacted. If the parties do reach agreement on whether certain information should be redacted, Defendant shall file a Motion under seal to address the dispute.
IT IS FURTHER ORDERED that Plaintiffs may use a mailing address other than their home address on public filings. Implementation of this Order is contingent upon Plaintiffs providing to the Court, under seal, their full legal names and residential address no later than August 1, 2026. Plaintiffs shall provide a copy of this Order to Defendant when serving the Defendant, or
as soon as practical after service of the Complaint.
s/Marilyn J_ Horan Marilyn J. Horan United States District Court Judge ATTN: L. B./ E.G. Mail Bin! 7211 Thomas Blvd. Pittsburgh, PA 15208
With respect to Plaintiffs’ mailing address, the docket sheet lists the first line of the address as, “L.B. and E.G.” However, Plaintiffs list the first line of the address of their Contact Information, as “Attn: L.B. /E.G. Mail Bin.” See ECF No. 3, at 9. Plaintiffs are requested to clarify the full and complete mailing address they intend to use by including a statement in their under-seal notice providing their full names and address, specifically identifying the correct address.
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