P.S., a minor v. Landowners of Oakland Airport Hotel, Ltd.
- Martinez-Olguin
- 4:25-cv-00698
- U.S. District Court · Northern District of California
- 3
In P.S. v. Landowners of Oakland Airport Hotel, Judge Martinez-Olguin allowed P.S.’s mother, M.S., to proceed anonymously in pretrial proceedings.
The order allows M.S., the mother and natural guardian of minor P.S., to proceed anonymously from the public in pretrial proceedings; it does not conceal her identity from the defendants.
What happened
In P.S., a minor v. Landowners of Oakland Airport Hotel, Ltd., P.S. asked the court to let her mother, M.S., use a pseudonym during pretrial proceedings. P.S. is described as a minor and an alleged child sex-trafficking survivor.
The court explained that parties normally must use their real names, but anonymity may be allowed when needed to protect against harm, harassment, ridicule, or embarrassment, and when that need outweighs prejudice to the other side and the public’s interest in knowing the person’s identity. The court found that disclosure could identify P.S. and risk retaliation because P.S. and M.S. share a last name.
Judge Araceli Martinez-Olguin granted the motion to proceed anonymously. The court found that keeping M.S.’s identity from the public would not prejudice the defendant and would still allow public scrutiny of the case’s key issues.
The detailed version
- P.S., a minor v. Landowners of Oakland Airport Hotel, Ltd. · No. 4:25-cv-00698
- Martinez-Olguin
- July 21, 2025
Background
P.S., a minor represented by her mother and natural guardian, M.S., moved for permission to allow M.S. to proceed anonymously in pretrial proceedings. The opinion describes P.S. as an alleged child sex-trafficking survivor. P.S. stated that she and M.S. share a last name, so making M.S.’s name public could make P.S.’s identity easy to determine. P.S. also argued that identifying either of them could risk retaliation from the alleged trafficker and expose them to harm, harassment, ridicule, or embarrassment.
P.S. had conferred with Defendant 150 Hegenberger Capital LLC, which did not oppose the motion. The deadline for any opposition passed without an opposition being filed.
Legal standard
The court explained that parties ordinarily must use their real names. Under Ninth Circuit precedent, however, a party may proceed anonymously when special circumstances justify secrecy. Relevant circumstances can include a risk of retaliatory physical or mental harm, the need to protect privacy in a sensitive and highly personal matter, or the risk of criminal prosecution from admitting intended illegal conduct. The need for anonymity must outweigh prejudice to the opposing party and the public’s interest in knowing the party’s identity.
Court’s reasoning
The court found that P.S. had established adequate grounds for M.S. to proceed anonymously. Because the allegations involved the sex trafficking of a child, the court found that disclosure could expose P.S. and M.S. to retaliation, harm, harassment, ridicule, or embarrassment. The court also found that allowing M.S. to remain anonymous from the public would not prejudice the defendant because P.S. did not seek to conceal M.S.’s identity from the defendants.
The court further concluded that the public could scrutinize the case’s key issues without learning M.S.’s identity. It therefore found that the need for anonymity outweighed the public’s interest in knowing her identity.
Disposition
Judge Araceli Martinez-Olguin granted Plaintiff’s motion to proceed anonymously. The ruling concerned the use of a pseudonym in pretrial proceedings and did not decide the underlying claims described in the opinion.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.