Doe v. Noem
- John Cronan
- 1:25-cv-03365
- U.S. District Court · Southern District of New York
- 1
In Doe v. Noem, Judge Cronan ordered Jane Doe to seek permission to use a pseudonym by May 2 or face dismissal without prejudice.
Jane Doe, whose ability to proceed under a pseudonym depends on filing a motion and obtaining the court’s permission.
What happened
In Doe v. Noem, Jane Doe filed the complaint using a pseudonym. The court said federal rules generally require a complaint to identify all parties by name.
The court said Jane Doe may proceed anonymously only if she first asks for and receives permission. It ordered her to file that request by May 2, 2025.
Judge Cronan stated that if Jane Doe did not file the request by that deadline, the court would dismiss the complaint without prejudice and without further notice. The opinion did not itself dismiss the complaint.
The detailed version
- Doe v. Noem · No. 1:25-cv-03365
- John Cronan
- Apr. 28, 2025
Background
Jane Doe filed the complaint under a pseudonym. The opinion does not describe the underlying claims.
Court’s Order
The court cited Federal Rule of Civil Procedure 10(a), which requires a complaint’s title to name all parties. It also cited Second Circuit precedent stating that a plaintiff may proceed under a pseudonym only after asking the court for permission and receiving it.
The court gave Jane Doe until May 2, 2025, to file a motion seeking permission to appear under a pseudonym. The court stated that it would dismiss the complaint without prejudice and without further notice if she failed to meet that deadline. The opinion does not say that the complaint was dismissed at that time.
Disposition
Judge John P. Cronan ordered Jane Doe to seek permission to proceed pseudonymously by May 2, 2025, or the complaint would be dismissed without prejudice. 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.