Doe v. Alexander
- Ronnie Abrams
- 1:25-cv-02241
- U.S. District Court · Southern District of New York
- 1
In Doe v. Alexander, Judge Abrams required Jane Doe to seek permission to proceed anonymously or face dismissal after removal.
Jane Doe, who must seek federal-court permission to proceed under a pseudonym; the defendants are affected by the requirement that the case comply with federal procedural rules.
What happened
In Doe v. Alexander, Jane Doe filed her complaint under a pseudonym in state court, where she had permission to do so. The defendants later removed the case to federal court.
The court explained that federal rules now govern the case and generally require a complaint’s title to name all parties. Jane Doe therefore cannot continue using a pseudonym unless she asks the federal court for permission and receives it.
The court ordered Jane Doe to file that request by March 31, 2025. Judge Ronnie Abrams stated that the court will dismiss the complaint if she does not meet that deadline.
The detailed version
- Doe v. Alexander · No. 1:25-cv-02241
- Ronnie Abrams
- Mar. 20, 2025
Background
Jane Doe filed the complaint in state court using a pseudonym, with that court’s permission. The defendants removed the action to the U.S. District Court for the Southern District of New York.
Pseudonym requirement
Judge Ronnie Abrams explained that federal procedural rules govern the case after removal. Federal Rule of Civil Procedure 10(a) generally requires the complaint’s title to identify all parties. Under the cited Second Circuit precedent, Jane Doe may proceed anonymously in federal court only if she first asks for and receives permission from the federal court.
Order
The court gave Jane Doe until March 31, 2025, to file a motion seeking permission to proceed under a pseudonym. The order states that the court will dismiss the complaint if she does not file that motion by the deadline. The order did not itself dismiss the complaint.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.