Doe v. Alexander
- John Cronan
- 1:25-cv-02077
- U.S. District Court · Southern District of New York
- 1
In Doe v. Alexander, Judge Cronan ordered Jane Doe to seek permission to use a pseudonym or face dismissal.
Jane Doe, whose ability to proceed under a pseudonym depends on filing a motion by March 31, 2025; the complaint may be dismissed if she does not do so.
What happened
In Doe v. Alexander, Jane Doe filed the complaint under a pseudonym in state court, and Tal Alexander removed the case to federal court.
Because federal procedural rules apply after removal, the court said a complaint generally must identify all parties by name. Jane Doe therefore must ask the court for permission to proceed under a pseudonym.
The court ordered Jane Doe to file that request by March 31, 2025, or it will dismiss the complaint. Judge John P. Cronan issued the order.
The detailed version
- Doe v. Alexander · No. 1:25-cv-02077
- John Cronan
- Mar. 19, 2025
Background
Jane Doe filed this action in state court using a pseudonym. On March 13, 2025, Tal Alexander removed the case to the U.S. District Court for the Southern District of New York. The court explained that the Federal Rules of Civil Procedure apply to a case after removal to federal court.
Court’s analysis
Federal Rule of Civil Procedure 10 requires the complaint’s title to name all parties. The court stated that Jane Doe therefore may not continue using a pseudonym unless she first asks the court for, and receives, permission to do so.
Order
The court gave Jane Doe until March 31, 2025, to file a motion seeking permission to proceed under a pseudonym. The court stated that it will dismiss the complaint if she does not file that motion by the deadline. The order does not itself dismiss the complaint.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.