Doe v. Grewal

Background

On August 19, 2024, Jane Doe filed a complaint against Nimarta Grewal and Marquita Grenot-Scheyer. The complaint alleged various harms connected to allegedly false accusations of sexual misconduct at Jane Doe's place of employment. The opinion states that the complaint asserted claims under 42 U.S.C. § 1983, the California Constitution, and California law concerning interference with economic advantage.

Rule 10 issue

Federal Rule of Civil Procedure 10(a) generally requires a complaint's title to name all parties. The court concluded from the complaint that Jane Doe had not complied with that rule because she did not name herself in the case caption and had not asked the court for permission to proceed under a pseudonym. A pseudonym is a substitute name used instead of a party's actual name. The court cited an earlier decision stating that a party had complied with Rule 10 by filing a complaint together with a motion to proceed under a pseudonym.

Order

The court ordered Jane Doe to show cause in writing within 14 days from the date of the order why the complaint should not be dismissed or why she should not otherwise be sanctioned for failing to comply with Rule 10(a). The order stated that, if Jane Doe filed an emergency motion showing good cause to proceed under a pseudonym by September 9, 2024, the court would review that motion as a response to the order.

The court warned that failing to comply could result in sanctions, including dismissal of the complaint, and any other relief the court considered appropriate. The order did not itself dismiss the complaint or impose sanctions.