Doe v. Alexander
- Ho
- 1:25-cv-02106
- U.S. District Court · Southern District of New York
- 1
In Jane Doe v. Alexander, Judge Ho ordered the pseudonymous plaintiff to seek permission by April 1 or face dismissal.
Jane Doe, whose use of a pseudonym in federal court is subject to a permission request; the complaint may be dismissed if she does not make the request by April 1, 2025.
What happened
Jane Doe filed this case in New York state court using a pseudonym, and that court allowed her to do so. A defendant later moved the case to federal court.
Judge Ho explained that federal procedural rules apply after removal. Those rules generally require a complaint to name all parties, so Jane Doe cannot continue using a pseudonym without the federal court’s permission.
The court ordered Jane Doe to request permission to proceed pseudonymously by April 1, 2025. Judge Ho stated that the court will dismiss the complaint if she does not make that request.
The detailed version
- Doe v. Alexander · No. 1:25-cv-02106
- Ho
- Mar. 20, 2025
Background
Jane Doe filed the complaint in the Supreme Court of the State of New York, County of New York, on February 18, 2025. That court allowed her to proceed under a pseudonym. A defendant removed the case to the U.S. District Court for the Southern District of New York.
Court’s Analysis
Judge Ho explained that federal procedural rules govern a case after it is removed to federal court. Federal Rule of Civil Procedure 10(a) requires the title of a complaint to name all parties. Under Second Circuit precedent, a plaintiff therefore may not proceed pseudonymously in federal court unless the plaintiff asks for and receives permission to do so.
Order
The court ordered Jane Doe to make any request for permission to proceed pseudonymously by April 1, 2025. The court stated that it will dismiss the complaint if no such request is made. The order did not decide the underlying claims.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.