Doe v. City of Apple Valley
- Patrick Schiltz
- 0:20-cv-00499
- U.S. District Court · District of Minnesota
- 5
John Doe 1 v. City of Apple Valley: Judge Schultz granted the plaintiffs’ request to litigate anonymously in their constitutional challenge to a housing ordinance.
The three plaintiffs may litigate this case using the pseudonyms John Doe 1, John Doe 2, and John Doe 3. The order also affects the City of Apple Valley, which will litigate against pseudonymous plaintiffs.
What happened
In John Doe 1, John Doe 2, and John Doe 3 v. City of Apple Valley, the plaintiffs challenged a city ordinance restricting where people convicted of sexual offenses may live and asked to use pseudonyms.
The court found that the plaintiffs’ identities had remained private, the case involved highly sensitive matters, and disclosure could expose them and their families to stigma or physical harm. The court also found little public need to know their identities because the case was largely about legal issues, and the City did not oppose anonymous litigation.
Judge Schultz granted the plaintiffs’ motion for leave to proceed anonymously. The order addressed only the use of pseudonyms and did not decide whether the ordinance was constitutional.
The detailed version
- Doe v. City of Apple Valley · No. 0:20-cv-00499
- Patrick Schiltz
- Mar. 5, 2020
Background
The plaintiffs challenged the constitutionality of a City of Apple Valley ordinance restricting where an individual convicted of a sexual offense may live within the City. They filed the lawsuit using the pseudonyms John Does 1, 2, and 3 and moved for permission to proceed anonymously. The City took no position on that motion.
Court’s analysis
The court explained that federal courts generally require parties to disclose their names, but may allow pseudonyms when privacy and safety concerns outweigh the public interest in knowing the litigants’ identities. The court considered the circumstances presented in the record, including that the plaintiffs’ true names had not become public despite early media interest; the sensitive nature of the litigation; the risk of stigma or retaliation; and the possibility of physical harm to the plaintiffs and their families.
The court noted that two plaintiffs were not required under Minnesota law to register on a public sex-offender registry or provide community notification. The third had been released from civil commitment with a “Level 1” risk designation. The court also noted that one plaintiff had a family, including children.
The court found no sufficiently strong reason to require disclosure. The City did not oppose anonymous litigation and therefore identified no prejudice from proceeding against pseudonymous plaintiffs. The court viewed the case as largely legal in nature, so knowing the plaintiffs’ identities would add little to the public’s ability to understand the case. The court also concluded that allowing pseudonyms could help people with similar claims come forward in the proposed class action, particularly because the plaintiffs alleged stigma and feared violence and sought no payment for serving as class representatives.
Ruling
The court held that the plaintiffs’ interest in protecting their identities outweighed the public interest in disclosure. It ordered that the plaintiffs’ Motion for Leave to Proceed Anonymously was GRANTED. This order did not resolve the constitutional challenge to the City ordinance or decide whether a class would be certified.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.