Doe v. Noem, 2:25-cv-00633

Plaintiff, identified as "John Doe," is an F-1 international student whose SEVIS record (student visa status) was terminated, leading to immigration consequences.
Doe has a pending misdemeanor DUI charge and asserts that public association with both the SEVIS termination and DUI would cause severe stigma and professional harm, particularly in the U.S. and China.
Doe sought to proceed under a pseudonym, citing fear of social, legal, and reputational harm, and the potential for harassment, including online and in the media.
Defendants, including government officials, oppose, arguing that Doe's identity is already known to them and his DUI is a matter of public record.
The court had previously granted a TRO blocking Doe’s removal; a motion for preliminary injunction is pending, but this ruling focuses solely on the pseudonym issue.
The docket in the case remains unsealed and public except for the plaintiff’s name and identifying information, which Doe seeks to keep private.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proceeding under pseudonym	Exposing Doe’s identity would risk severe social, professional, and personal harm, including harassment and reprisal, especially given high-profile media, social stigma, and risks of online doxing.	Doe’s identity is already known to Defendants; DUI is publicly available; public has overriding interest in transparent judicial proceedings.	Doe allowed to proceed as "John Doe"; risk of harassment outweighs minimal prejudice to Defendants and public.
Severity and reasonableness of threatened harm	Doe faces culturally severe career and family consequences, especially as a noncitizen with a criminal charge.	Harm is typical of all criminal defendants; not especially severe; fears removal are irrelevant to disclosure.	Plaintiff’s fears of harassment in context are reasonable and severe, especially online.
Prejudice to Defendants	Defendants already know Doe’s identity, so no prejudice by continuing anonymity.	Anonymity impairs the public’s right to open courts and transparency.	No prejudice to Defendants; anonymity does not impair case defense.
Public Interest in disclosure	Anonymity does not impair the public’s ability to review substantive legal issues or case filings.	Plaintiff’s identity is of public interest in open proceedings.	Public interest remains protected; only Doe’s name is withheld.

Does I thru XXIII v. Advanced Textile Corp., 214 F.3d 1058 (9th Cir. 2000) (establishes factors for proceeding under a pseudonym)
Doe v. Kamehameha Sch./Bernice Pauahi Bishop Est., 596 F.3d 1036 (9th Cir. 2010) (considers social context and reasonableness for anonymity)
James v. Jacobson, 6 F.3d 233 (4th Cir. 1993) (public interest in disclosure is less when the government is defendant)
Doe v. Merten, 219 F.R.D. 387 (E.D. Va. 2004) (anonymity may be more justified when challenging government action)