Stephanie Ricketts v. Titusville Area School District

• Court: Court of Appeals for the Third Circuit
• Decided: August 18, 2025
• Docket: 24-2569
• Status: Published

Opinion

PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _______________

No. 24-2569 _______________

STEPHANIE RICKETTS, as parent of L.G., a minor, Appellant

v.

TITUSVILLE AREA SCHOOL DISTRICT; ROCHELLE CRESSMAN _______________

On Appeal from the United States District Court for the Western District of Pennsylvania (D.C. No. 1:21-cv-00129) District Judge: Honorable Susan Paradise Baxter _______________

Submitted April 28, 2025

Before: KRAUSE, BIBAS, and MONTGOMERY-REEVES, Circuit Judges

(Filed: August 18, 2025) __________________________

OPINION OF THE COURT __________________________

PER CURIAM

One way in which courts protect the right of public access to judicial proceedings is

by requiring, as a general rule, that cases proceed using the real names of the parties. In cases involving minor children, however, a child’s privacy interests outweigh the public’s

interest in knowing their real name. For this reason, the Federal Rules of Civil Procedure,

the Federal Rules of Appellate Procedure, and our Local Rules mandate that the names of

all minor children be redacted or replaced by initials in all documents filed with the court,

Fed. R. Civ. P. 5.2(a)(3); Fed. R. App. P. 25(a)(5); Third Circuit L.A.R. 113.12(a)(2), and

failure to comply with such rules may be grounds for sanctions. Fed. R. App. P. 46(c).

Litigation, however, can be a lengthy ordeal, so it is not uncommon for a minor

child to reach adulthood before a case has fully resolved. That occurred here when L.G.—

a minor victim of sexual abuse—turned eighteen in between the filing of the complaint and

the District Court’s order granting summary judgment. Counsel, uncertain as to their

obligations in this scenario, included L.G.’s unredacted name in certain filings before the

District Court and before us on appeal. Because we had not spoken clearly on this issue

before, we will not impose sanctions, though we will take this opportunity to clarify the

relevant rules.

I.

In 2021, Plaintiff-Appellant Stephanie Ricketts brought claims on behalf of her

child, L.G., arising out of sexual abuse he suffered at the hands of a teacher while he was

a minor. Pursuant to the applicable rules, Ms. Ricketts’ counsel used the initials “L.G.” in

the complaint and both sides’ counsel understood their duty to redact or initialize L.G.’s

name and those of any other minor children in all documents filed with the Court. But by

the time the District Court granted summary judgment in favor of one of the defendants,

the Titusville Area School District, L.G. had turned eighteen. That meant that L.G. was 2 no longer a minor when Ms. Ricketts appealed the District Court’s decision and the parties

filed merits briefs and appendices in the matter now before us.

Upon review of those materials, we discovered that the appendices included L.G.’s

unredacted name, as well as the unredacted names of other individuals who were minors

at the time of the events described. We therefore sua sponte placed these unredacted

appendices under seal and ordered the parties to submit new redacted versions and to show

cause why sanctions were not warranted. Both parties responded by apologizing for their

error, with the School District further explaining that it had understood the Federal Rules

and our rules to require redaction only of the names of persons who were minor children

at the time of filing.

II.

We begin with counsel’s obligations before the District Court. Because L.G. was a

minor at the time the complaint was filed, Rule 5.2 required counsel to redact his name in

all court filings. See Fed. R. Civ. P. 5.2(a)(3). When L.G. turned 18 during the course of

litigation, however, that rule no longer applied on a prospective basis. At that point,

counsel could have moved to continue to allow L.G. to proceed anonymously by

demonstrating that doing so would be necessary to prevent serious harm. See In re Avandia

Mktg., Sales Pracs. & Prod. Liab. Litig., 924 F.3d 662, 672 (3d Cir. 2019). Depending on

the nature and circumstances of the case, minors who reach adulthood during the course of

litigation may be able to justify such treatment as a result of their continuing interests in

avoiding the embarrassment, stigma, and potential for retaliation that can attend public

disclosure. See, e.g., Katie M. and A.M. v. Aetna Life Ins. Co., 2025 WL 934458, at *1-2 3 (D. Utah, Mar. 27, 2025); M.V. v. United Healthcare Ins. Co., 2025 WL 463308, at *2 (D.

Utah, Feb. 11, 2025); N.E. v. Blue Cross Blue Shield of N.C., 2023 WL 2696834, at *15

(M.D.N.C. Feb. 24, 2023); Doe v. USD No. 237, 2017 WL 3839416, *11 (D. Kan. Sept. 1,

2017). Those criteria would seem to weigh heavily on the side of redaction in the case of

a minor victim of sexual assault, but no such motion was filed, so counsel was not required

by Rule 5.2 or by order to anonymize submissions after L.G. turned 18.

Before L.G. turned 18, however, his counsel filed at least three documents that did

not redact his name, including one document that was also filed with the appendix on

appeal. These filings clearly violated Rule 5.2, but because they originated in the District

Court we have no occasion to impose sanctions for these failures to redact.1

Turning to counsel’s obligations on appeal, we identified several unredacted

documents filed publicly as part of the parties’ supplemental appendix on appeal. These

documents had originally been filed under seal in the District Court, meaning there was no

Rule 5.2 violation with respect to them. But the District Court never ordered those

documents unsealed, and under our rules, any “records sealed in the district court and not

unsealed by order of [this] court must not be included in the paper appendix.” See Third

Cir. L.A.R. 30.3(b). Thus, it appears the parties violated our Local Rules by filing

previously sealed information on the public docket. Nonetheless, because both parties have

1 We note that the unredacted documents on the District Court’s docket have since been sealed. 4 expressed sincere regret and explained their good-faith efforts to comply with the rules, we

do not believe that violation warrants sanctions.

III.

For the foregoing reasons, we will not impose sanctions on either party.