r1r STANDING COMMITTEE ON RULES OF PRACTICE - Maryland ...

Source: This Rule is derived from former Rule 203 a, b, and c
and the 1966 version of Fed. R. Civ. P. 17 (a).
REPORTER’S NOTE
A judge of the Court of Appeals requested that the Rules
Committee study whether the Rules should be amended by the
addition of a general “John Doe” rule concerning the right of a
party to proceed anonymously. The “John Doe” issue was discussed
in Doe v. Shady Grove Hospital, 89 Md. App. 351 (1991). In that
case, the Court of Special Appeals held that papers filed in an
action may be filed in the name of “John Doe” if protecting the
confidentiality of a party’s identity serves a compelling
government interest or provides a necessary right to privacy.
After its review of Doe and procedures in other jurisdictions,
and given the infrequency of this type of filing, the Committee
recommends that Rules 2-201 and 3-201 be amended by the addition
of a cross reference to the Doe case at the end of each Rule.
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