Doe v. Roe
3:25-cv-00249
M.D. Tenn.May 19, 2025Background
- Plaintiff Jane Doe sued her former romantic and business partner, John Roe, and his LLC, alleging unlawful disclosure of intimate images under federal law (15 U.S.C. § 6851), part of the Violence Against Women Act Reauthorization Act of 2022.
- Plaintiff alleges that after their relationship ended, Roe uploaded identifiable intimate photos and videos of her to social media accounts, allegedly exceeding the scope of her authorization.
- Plaintiff moved to proceed using pseudonyms for all parties and to file documents with true names under seal, citing privacy concerns due to the nature of the images and relationship.
- Defense opposed anonymity, moved for a more definite statement, and sought to require Plaintiff to amend the complaint to use real names and specify when claims accrued.
- The Court considered the motions in the context of the presumption of open judicial proceedings and past handling of similarly sensitive cases without pseudonyms.
- The Court found that the facts were already public and the interests in transparency and accountability were not outweighed by Plaintiff's privacy interests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Use of pseudonyms in public docket | Privacy interests outweigh public interest due to sensitive, intimate nature of facts | Presumption of openness; no justification for pseudonyms | Motion to proceed anonymously DENIED |
| Filing documents under seal | True names should be kept under seal to protect privacy | Transparency requires disclosure | Motion to file under seal DENIED |
| Need for more definite statement | Complaint is sufficiently clear as is | Plaintiff must clarify real names and claim accrual dates | Motion for more definite statement DENIED |
| Accrual dates for claims | Dates are sufficiently alleged | Must specify accrual dates | Court found enough detail to frame a response; DENIED |
Key Cases Cited
- Doe v. Porter, 370 F.3d 558 (6th Cir. 2004) (sets standard for proceeding under pseudonym and factors for anonymity in litigation)
- Citizens for a Strong Ohio v. Marsh, 123 F. App’x 630 (6th Cir. 2005) (affirming exceptional circumstances for pseudonym use)
- Doe v. Blue Cross & Blue Shield United of Wisconsin, 112 F.3d 869 (7th Cir. 2010) (criticizing routine use of pseudonyms in sensitive cases)