What is the test for using a pseudonym in a criminal case?

MultiRegion, United States of America

The following excerpt is from United States v. Doe, 778 F.3d 814 (9th Cir. 2015):

¹ We grant the defendant's unopposed motion for use of a pseudonym in this opinion because this is an unusual case where the defendant may face a risk of serious bodily harm if his role on behalf of the Government were disclosed to other inmates. United States v. Doe, 655 F.2d 920, 922 n. 1 (9th Cir.1980).
¹ We grant the defendant's unopposed motion for use of a pseudonym in this opinion because this is an unusual case where the defendant may face a risk of serious bodily harm if his role on behalf of the Government were disclosed to other inmates. United States v. Doe, 655 F.2d 920, 922 n. 1 (9th Cir.1980).

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What is the test for using a pseudonym in a criminal case?

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