Doe v. Department of Homeland Security, 2:22-cv-05172

Plaintiff is a Chinese national who applied for asylum and withholding of removal in 2015 and filed this suit seeking a writ of mandamus under the APA to compel USCIS to schedule an interview.
Doe initially filed her complaint and exhibits on the public docket but then moved to seal all case records, citing safety risks to herself and relatives in China if her asylum application information were disclosed.
The court issued a show-cause order and provisionally sealed the complaint exhibits; the government defendants did not file an opposition within the response period.
The complaint’s exhibits include DHS receipt, a biometrics appointment notice, and email communications with a local asylum office—materials the court found sensitive.
Doe relied on 8 C.F.R. § 208.6 (confidentiality of asylum applications); the court balanced that confidentiality interest and risk of harm against the public’s common-law and First Amendment right of access.
The court sealed asylum-application–related records and any filings containing Doe’s real name, denied sealing the entire case, and allowed Doe to proceed pseudonymously as “Jane Doe”; it ordered refiled public versions substituting the pseudonym and reminded defendants of 8 C.F.R. § 208.6.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court should seal case records and exhibits	Seal records because disclosure of asylum-application details would risk retaliation to Doe and family; §208.6 bars disclosure	No responsive filing; public-access presumption favors openness	Court sealed asylum-application–related exhibits and any filings revealing Doe’s identity but denied sealing the entire case
Whether plaintiff may proceed anonymously	Allow pseudonym to protect safety while keeping case public	No prejudice to defendants; defendants did not oppose	Court permitted Doe to proceed as “Jane Doe,” ordered refiled public pleadings using the pseudonym

June Medical Servs., L.L.C. v. Phillips, 22 F.4th 512 (5th Cir.) (requires document-by-document balancing of public access against privacy interests)
Le v. Exeter Fin. Corp., 990 F.3d 410 (5th Cir.) (public-access balancing framework)
Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185 (2d Cir.) (explains importance of naming parties and limited exceptions for anonymity)
Doe v. Stegall, 653 F.2d 180 (5th Cir.) (factors for permitting pseudonymous plaintiffs)
S. Methodist Univ. Ass'n of Women Law Students v. Wynne & Jaffe, 599 F.2d 707 (5th Cir.) (anonymity where plaintiffs challenge government activity or constitutional issues)
Roe v. Ingraham, 364 F. Supp. 536 (S.D.N.Y.) (permitting pseudonyms to protect sensitive personal information in constitutional challenges)