Doe v. Dehlinger
- Pitts
- 5:23-cv-06657
- U.S. District Court · Northern District of California
- 2
In Jane Doe v. Dehlinger, Judge Pitts denied sealing and another extension, then dismissed the case without prejudice after Doe missed the deadline.
The pro se plaintiff, Jane Doe, whose requests to seal records and extend the filing deadline were denied and whose case was dismissed without prejudice; the defendants are affected by the case’s dismissal.
What happened
In Jane Doe v. Dehlinger, the pro se plaintiff repeatedly sought permission to proceed as “Jane Doe.” The court had denied that request and ordered her to file an amended complaint using her legal name by August 30, 2024.
The plaintiff asked to seal the entire docket in this case, another federal case, and related California state cases. She also requested another extension to file her amended complaint. The court denied both requests, explaining that court records are generally open and that it could not seal files in cases assigned to other judges or pending in other courts.
Because the plaintiff did not file an amended complaint by the deadline, Judge P. Casey Pitts dismissed this action without prejudice. The order states that she may file a new case asserting the same claims later, if the claims are timely.
The detailed version
- Doe v. Dehlinger · No. 5:23-cv-06657
- Pitts
- Sept. 12, 2024
Background
The pro se plaintiff repeatedly asked to proceed under the pseudonym “Jane Doe.” On April 9, 2024, the court denied that request and ordered her to file an amended complaint. The court later granted three additional extensions, with the latest deadline set for August 30, 2024. That extension required the amended complaint to use the plaintiff’s legal name and stated that no further extensions would be granted.
The plaintiff did not file an amended complaint by August 30. On September 3, 2024, she filed a letter requesting an additional extension and asking the court to seal all files in this case, in case 22-cv-06822-BLF, and in related California state-court cases.
Request to Seal
The court denied the request to seal. It explained that court records carry a strong presumption of public access and that parties seeking to seal documents must limit sealing to the smallest necessary number of documents or portions. The plaintiff sought to seal the entire case docket. The court stated that embarrassment, possible incrimination, or exposure to further litigation did not justify sealing the individual documents or portions at issue, much less the entire docket. The court also stated that it lacked authority to seal files in cases assigned to other judges or pending in other jurisdictions.
Extension and Disposition
The court denied the request for another filing extension because the plaintiff had received ample time and had previously been told that no further extensions would be granted. The court dismissed the action without prejudice because the plaintiff failed to file the amended complaint by the deadline. The order states that she may file a new case asserting the same claims later, assuming the claims are timely.
Judge P. Casey Pitts signed the order on September 12, 2024.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.