Doe v. Alexander
- James Oetken
- 1:25-cv-02109
- U.S. District Court · Southern District of New York
- 3
In Doe v. Alexander, Judge Oetken denied Jane Doe’s request to sue anonymously and ordered her to decide whether to proceed under her real name.
Jane Doe must decide whether to proceed under her real name and, if she does, file an amended complaint using that name. Tal Alexander and the public are affected by the court’s determination that the case should not proceed anonymously.
What happened
In Doe v. Alexander, Jane Doe sued Tal Alexander for sexual battery and violating New York City’s law protecting victims of gender-motivated violence. After Alexander moved the case to federal court, Doe asked to keep using a pseudonym.
The court said federal rules generally require parties to be named and that anonymity must be balanced against public access and harm to the defendant. It found that Doe had not shown a specific risk of harm beyond the sensitivity and potential emotional impact of the allegations, and that keeping her name secret would unfairly limit public scrutiny of the case.
Judge Oetken denied Doe’s motion to proceed under a pseudonym. The court ordered her to file a letter within seven days stating whether she will proceed under her real name; if she does, she must file an amended complaint using that name within 14 days after the letter.
The detailed version
- Doe v. Alexander · No. 1:25-cv-02109
- James Oetken
- July 17, 2025
Background
Jane Doe filed an anonymous complaint in New York County Supreme Court against Tal Alexander, asserting claims for sexual battery and violation of New York City’s Victims of Gender-Motivated Violence Protection Act. Alexander removed the case to the U.S. District Court for the Southern District of New York, invoking federal diversity jurisdiction. The court directed Doe to seek permission to proceed under a pseudonym, and she filed that motion. Alexander opposed it.
Legal standard
Federal Rule of Civil Procedure 10(a) generally requires all parties to be named in the complaint’s title. The court explained that a plaintiff seeking anonymity must balance her interest in confidentiality against the public interest in disclosure and any prejudice to the defendant. Relevant considerations include the sensitivity of the lawsuit, the risk of harm, the plaintiff’s circumstances, prejudice to the defendant, the public interest, and alternatives to confidentiality.
Court’s analysis
The court concluded that Doe had not overcome the strong presumption of public access to judicial proceedings. Even assuming the truth of her allegations, the court found that she alleged one incident rather than an ongoing campaign of intimidation or violence. It also found her arguments about retaliation conclusory. The court noted that Alexander would still have access to Doe’s discoverable information and could depose her and other witnesses, so keeping her identity secret from the public would not affect his ability to retaliate against her.
The court further determined that the sensitive nature of sexual-assault allegations and Doe’s concern that public disclosure could cause additional trauma were insufficient, on the facts described in the opinion, to justify anonymous pleading. It also found that allowing Alexander to defend himself publicly while Doe remained anonymous would prejudice him and that the public interest in knowing the identities of litigants was especially significant because the allegations were made against a public figure.
Disposition
The court denied Doe’s motion to proceed under a pseudonym. It ordered her to file a letter within seven days of publication of the opinion stating whether she intends to proceed using her real name. If she elects to proceed, the court ordered that her real name be used in future filings and that she file an amended complaint using that name within 14 days of the letter. The court stated that it would consider the other pending motions in due course and directed the Clerk of Court to terminate the motion at docket entry 8.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.