Jane Doe v. The College of New Jersey, 997 F.3d 489

Doe was hired as a tenure-track assistant professor at The College of New Jersey in 2016 and alleges pregnancy- and gender-based comments by administrators after childbirths.
After becoming pregnant with a fourth child, Doe alleges she was reassigned to a more burdensome class, received materially worse peer reviews, had a disciplinary record placed in her personnel file, and was not reappointed in 2019.
Doe filed an EEOC charge, received a right-to-sue letter, and brought Title VII and NJLAD claims for discrimination and retaliation.
Shortly after filing suit, Doe moved to proceed anonymously; the magistrate judge denied the motion and the district court affirmed after applying this Circuit’s pseudonymity factors from Doe v. Megless, but stayed enforcement pending appeal.
On appeal the College contested jurisdiction; the Third Circuit addressed (1) whether the denial is immediately appealable under the collateral order doctrine and (2) whether the district court abused its discretion in denying anonymity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an order denying a motion to proceed anonymously is immediately appealable under the collateral order doctrine	Doe argued appealable because denial conclusively removes anonymity and cannot be remedied after identity is publicly disclosed	TCNJ argued the court lacks jurisdiction because this Circuit has not recognized such appeals under the collateral order doctrine	Court: Yes. Denials meet Cohen/Mohawk prongs (conclusive, important/separable, effectively unreviewable); joins other circuits in allowing immediate appeal
Whether the district court abused its discretion in denying Doe’s motion to proceed anonymously under Megless factors	Doe argued she reasonably feared harassment, reputational/economic harm, professional stigma, and disclosure of sensitive family/pregnancy information; district court misweighed several Megless factors	TCNJ characterized this as a garden‑variety employment discrimination case without exceptional risk and urged affirmance	Court: No abuse of discretion. The district court applied Megless, reasonably weighed factors (public interest, lack of showing that denial would deter similarly situated litigants, no illegitimate motives), and concluded Doe did not show a risk of severe harm warranting anonymity

Cohen v. Beneficial Indus. Loan Corp., 337 U.S. 541 (1949) (establishes collateral order doctrine)
Mohawk Indus., Inc. v. Carpenter, 558 U.S. 100 (2009) (three‑prong test for immediately appealable collateral orders)
Doe v. Megless, 654 F.3d 404 (3d Cir. 2011) (Third Circuit multi‑factor test for proceeding pseudonymously)
Doe v. Vill. of Deerfield, 819 F.3d 372 (7th Cir. 2016) (orders denying anonymity are immediately appealable)
Does I thru XXIII v. Advanced Textile Corp., 214 F.3d 1058 (9th Cir. 2000) (recognizing severe retaliation fears can justify anonymity)
James v. Jacobson, 6 F.3d 233 (4th Cir. 1993) (noting anonymity denials may present serious questions warranting immediate review)
United States v. Mitchell, 652 F.3d 387 (3d Cir. 2011) (en banc) (discusses importance/separateness requirement under collateral order analysis)