In Doe v. Shady Grove Adventist Hospital, 89 Md. App. 351, 598 A.2d 507 (1991), the Court reversed an order by a circuit court in a civil case denying the plaintiff's request to proceed anonymously. The plaintiff's cause of action was based on a claimed privacy violation. Specifically, the plaintiff sued a hospital, alleging that certain of its employees had improperly disclosed that he was suffering from the disease AIDS, thus breaching his right to medical privacy and causing him to suffer damages as a result. He wished to use a pseudonym in his civil action because, if he did not, the injury he claimed he had suffered already, and that he was seeking to remedy, would be exacerbated. The Court pointed out that it is well established in criminal law that the right to public access to trials and to records is inherent in the First Amendment to the federal constitution and in Article 40 of the Maryland Declaration of Rights; and that "the policy reasons enunciated by the Supreme Court in support of public access to criminal proceedings apply with equal force to civil proceedings." 89 Md. App. at 359. The Court noted that, historically, both criminal and civil proceedings have been presumptively open to the public, both in terms of access to the court and to court records. Id. The right of public access is not absolute, however, and "may be limited 'when an important countervailing interest is shown.'" Id. at 360.