DOE v. BUTLER UNIVERSITY, 1:22-cv-01828

John Doe, a former undergraduate, sued Butler University for breach of contract and unjust enrichment related to the university’s handling of a stalking complaint made against him.
Plaintiff initially filed the lawsuit under a pseudonym and requested to continue under this status after the court questioned its necessity.
The stalking investigation by Butler concluded with a finding in Doe's favor—he was not found responsible.
Doe asserted that revealing his identity would expose him to harm based on his sexual orientation and that it would disclose intimate, personal details.
Butler opposed continued pseudonymity, arguing no exceptional circumstances justified it and emphasizing public interest in transparency.
The court’s ruling was prompted by recent Seventh Circuit guidance on pseudonymity in Title IX and similar university-related cases.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether exceptional circumstances justify Plaintiff proceeding under a pseudonym	Disclosure risks substantial harm, retaliation, and reveals intimate facts; would also harm non-parties; no public interest in disclosure	Risk of harm speculative and irrelevant to contract claims; Protective Order protects non-parties; public interest in openness outweighs privacy	No exceptional circumstances; Plaintiff must proceed under legal name or dismiss case

Doe v. Trustees of Indiana University, 101 F.4th 485 (7th Cir. 2024) (norm in federal litigation is use of litigants’ real names; exceptional circumstances required for pseudonyms)
Doe v. Loyola University Chicago, 100 F.4th 910 (7th Cir. 2024) (anonymity in Title IX suits must be justified case by case; strong public interest in open courts)
Doe v. Blue Cross & Blue Shield United of Wisconsin, 112 F.3d 869 (7th Cir. 1997) (fictitious names are disfavored except in exceptional circumstances)
E.A. v. Gardner, 929 F.3d 922 (7th Cir. 2019) (adult litigants require exceptional circumstances for anonymity)