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Doe v. Megless
654 F.3d 404
| 3rd Cir. | 2011
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Background

  • Doe sues public officials and entities under 42 U.S.C. § 1983 for an email/flyer distribution labeling him suspicious near schools; flyer included his name, photo, and personal data.
  • Email by Megless (Security Director) and Fonock (Chief of Police) directed recipients to contact police about Doe; flyer alleged to portray him as mentally unstable and dangerous.
  • Doe sought to proceed pseudonymously; district court required real-name filing and warned of dismissal with prejudice for noncompliance.
  • Doe filed amended complaint; district court denied anonymity and granted dismissal under Rule 41(b) after Doe refused to proceed under his real name.
  • The court held the email and flyer implicated public figures/government entities; Doe’s claims relate to alleged violations of movement, privacy, and wrongful data handling.
  • Appellate panel reviews denial of anonymity for abuse of discretion and affirms dismissal under Rule 41(b).

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the district court abused its discretion denying anonymity Doe argues secrecy was justified due to fear of severe harm Defendants contend public interest in open proceedings outweighed anonymity No abuse; district court properly balanced interests
Whether dismissal under Rule 41(b) was proper Doe contends lesser sanctions could suffice Court found willful nonprosecution and Poulis factors supported dismissal Dismissal affirmed; two independent grounds established

Key Cases Cited

  • Doe v. C.A.R.S. Protection Plus, Inc., 527 F.3d 358 (3d Cir. 2008) (affirmed balancing approach to anonymity)
  • Provident Life and Accident Co. v. Advanced Medical Inst., 176 F.R.D. 464 (E.D. Pa. 1997) (non-exhaustive factors for anonymity safety weighing)
  • Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185 (2d Cir. 2008) (nine-factor framework for anonymity analysis)
  • Advanced Textile Corp. v. City of New York, 214 F.3d 1068 (3d Cir. 2000) (recognition of balancing factors in anonymity decisions)
Read the full case

Case Details

Case Name: Doe v. Megless
Court Name: Court of Appeals for the Third Circuit
Date Published: Aug 1, 2011
Citation: 654 F.3d 404
Docket Number: 10-4110
Court Abbreviation: 3rd Cir.