John Doe v. Village of Deerfield, 819 F.3d 372

"John Doe" sued the Village of Deerfield, Batchelder, and Zalesny under § 1983 (equal protection) and Illinois malicious prosecution law, alleging false statements led to his arrest and prosecution that was later expunged.
Doe filed his complaint using a fictitious name; defendants moved to dismiss partly for failure to use his true name per Fed. R. Civ. P. 10(a).
Doe moved for leave to proceed anonymously, arguing disclosure would defeat his expungement and cause embarrassment.
The district court denied leave to proceed anonymously (finding no "exceptional circumstances") and granted dismissal without prejudice, allowing refiling under his true name; it stayed proceedings pending appeal.
The Seventh Circuit accepted jurisdiction and reviewed whether denials of anonymity are immediately appealable and whether the district court abused its discretion in denying anonymity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are denials of motions to proceed anonymously immediately appealable?	Denial should be reviewable now to protect anonymity before identity is exposed.	Not final; appeal should await final judgment.	Yes — falls within the collateral order doctrine and is immediately appealable.
Does Doe show "exceptional circumstances" justifying anonymity?	Expungement purpose and embarrassment from disclosure warrant anonymity.	Public right to open proceedings and prejudice to defendants outweigh embarrassment.	No — Doe failed to show exceptional circumstances.
Standard of review for anonymity denials	N/A (procedural)	N/A	Abuse-of-discretion standard applies.
Effect of failing to disclose true name under court/local rules	N/A	Noncompliance undermines recusal/ transparency and supports denial.	Failure to comply with 7th Cir. R. App. P. 26.1 supports district court's approach.

Cohen v. Beneficial Indus. Loan Corp., 337 U.S. 541 (Sup. Ct. 1949) (establishes collateral order doctrine)
Mohawk Indus., Inc. v. Carpenter, 558 U.S. 100 (Sup. Ct. 2009) (elements for collateral order doctrine)
Does I thru XXIII v. Advanced Textile Corp., 214 F.3d 1058 (9th Cir. 2000) (denials of anonymity are immediately appealable)
Doe v. City of Chicago, 360 F.3d 667 (7th Cir. 2004) (standard and precedents for anonymity in this circuit)
Blue Cross & Blue Shield United of Wis. v. Doe, 112 F.3d 869 (7th Cir. 1997) (requires "exceptional circumstances" to proceed anonymously)
Gulfstream Aerospace Corp. v. Mayacamas Corp., 485 U.S. 271 (Sup. Ct. 1988) (collateral-order related discussion)
Doe ex rel. Doe v. Elmbrook Sch. Dist., 658 F.3d 710 (7th Cir. 2011) (examples of when anonymity may be warranted)