Doe v. Combs
1:24-cv-08852
| S.D.N.Y. | Mar 28, 2025Background
- Plaintiff, pseudonymously as "John Doe," alleges sexual assault by Sean Combs at a 2022 New York City party, claiming he was drugged and assaulted, resulting in emotional distress.
- The complaint was initially filed anonymously, and the Court temporarily allowed Doe to proceed anonymously until a renewed motion could be decided.
- After service of the complaint and appearances by defendants, Doe timely renewed his motion for anonymity.
- Defendants opposed, arguing for public disclosure of Doe’s identity.
- The Court conducted a detailed balancing of the Second Circuit's ten-factor test for pseudonymous litigation, as laid out in Sealed Plaintiff v. Sealed Defendant.
- The Court concluded that Doe's assertions and evidence were insufficient to overcome the presumption against anonymity in civil litigation involving private parties and ordered Doe to amend the complaint to include his real name.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can plaintiff proceed anonymously in this case? | Plaintiff’s privacy and trauma require anonymity, sensitive nature of claim. | Serious allegations against public figure require open proceedings and disclosure. | No. Anonymity denied. |
| Whether harm from identification justifies anonymity | Disclosure would cause mental distress and retraumatization. | No specific, corroborated harm shown; general embarrassment is not enough. | No. No particularized, proven harm. |
| Does disclosure harm public or private interests more? | Public interest is mainly knowing the accused, not the accuser’s identity. | Public has strong interest in knowing litigants’ identities, especially public cases. | Public interest favors disclosure. |
| Will anonymity prejudice defendants? | Prejudice is minimal; defendants will have access to discovery information. | Defendants need plaintiff’s identity for discovery, fairness, symmetrical fact-finding. | Anonymity would prejudice defendants. |
Key Cases Cited
- Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185 (2d Cir. 2008) (sets out ten-factor test for granting pseudonymity in litigation)
- United States v. Pilcher, 950 F.3d 39 (2d Cir. 2020) (clarifies that pseudonyms are exceptions, not the rule, in federal litigation)
- Doe v. Weinstein, 484 F. Supp. 3d 90 (S.D.N.Y. 2020) (victims’ embarrassment and public scrutiny not sufficient for pseudonymity)
- Doe v. Shakur, 164 F.R.D. 359 (S.D.N.Y. 1996) (public humiliation/embarrassment insufficient for pseudonymous litigation)