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Free Speech

Disbarred Lawyer Can't Pseudonymously Challenge Her Disbarment

Eugene Volokh | 6.16.2026 2:43 PM

From the Tenth Circuit today in Roe v. Colo. Jud. Dep't, decided by Judge Richard Federico and Judges Scott Matheson and Nancy Moritz:

Appellant previously held a Colorado law license. As alleged in her complaint, Colorado attorney regulators first found her disabled from the practice of law and then disbarred her. The Colorado Supreme Court later precluded her from representing herself in Colorado courts. She then filed this pro se federal civil action against the Colorado Judicial Department and officials involved in the disability and disciplinary proceedings, alleging those proceedings were discriminatory and unlawful in numerous ways.

Appellant filed her complaint using the pseudonym Jane Roe instead of her real name…. Nonparties the Colorado Freedom of Information Coalition (CFIC) and Eugene Volokh filed an objection to her motion to restrict….

"… Federal Rule of Civil Procedure 10(a) requires the names of all parties to appear in the caption of a complaint, and the title of all other pleadings must name the first party on each side." … "'[L]awsuits are public events' and 'there is no legal right in parties to be allowed anonymity.'" "'Ordinarily,........

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