Thursday, January 15, 2026
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C.A. Panel Bares Identity of Appellant Who Litigated in Superior Court as ‘Mr. BW’
By a MetNews Staff Writer
Div. Seven of the Court of Appeal for this district, in an opinion filed yesterday. bucked the trend of automatically using a pseudonym for a party where it was done in the trial court, identifying by his true name a man who sued in the Los Angeles Superior Court as “Mr. B.W.”
Justice Natalie P. Stone authored the unpublished opinion in case No. E086401 which the appeals court re-captioned, “Williams v. Wolfe.” In the trial court, it was titled “Mr. BW, Individually, on Behalf of Himself the General Public and on Behalf of All Other Persons and Class Similarly Situated vs. Umilta Maria Wolfe.”
Los Angeles Superior Court Judge Bruce G. Iwasaki dismissed the case with prejudice based on Williams not having served any of the defendants within two years of filing the complaint. He later denied a motion to vacate the order of dismissal.
Appeal Dismissed
Stone declared that the Court of Appeal has no jurisdiction over the appeal from the judgment because it was not timely. She found no basis to reverse the motion to vacate.
The justice said in a footnote:
“Williams filed his case under the name Mr. BW. The trial court asked Williams under oath if his real name was Brian Williams, and Williams initially ‘plead[ed] the 5th amendment and refuse[d] to answer the Court’s question regarding his true name:’ At a later hearing, however, Williams stated ‘Mr. Williams’ was his ‘true name.’ Because Williams did not obtain court authorization to appear under the pseudonym Mr. BW, we refer to him by his real name.”
‘Rarest of Circumstances’
She pointed to the Nov. 21 opinion by Justice Anne K. Richardson of this district’s Div. Two which, in turn, quoted a 2020 Sixth District decision that says:
“Outside of cases where anonymity is expressly permitted by statute, litigating by pseudonym should occur ‘only in the rarest of circumstances.’ ”
The phrase “only in the rarest of circumstances” was taken from the California Supreme Court’s 1999 opinion in NBC Subsidiary (KNBC-TV), Inc. v. Superior Court which declared that trial courts should “close proceedings only in the rarest of circumstances.”
Stone also quoted Acting Presiding Justice Maurice Sanchez of the Fourth District’s Div. Three as saying in his Feb, 28 opinion in Santa Ana Police Officers Assn. v. City of Santa Ana:
“Unless a statute specifically allows a plaintiff to sue under a pseudonym, a plaintiff must obtain court authorization in order to appear anonymously.”
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