Strain, Casey v. Murphy, Angela, 3:25-cv-00017

Plaintiff Casey Strain alleges that defendant Jane Doe (aka Angela Benedict/Murray) made false statements to his probation agent, leading to the revocation of his extended supervision and his detention for over three months.
Strain claims Doe accused him of contacting and doxxing her via Reddit in violation of his supervision conditions.
Strain, a Wisconsin citizen, asserts Doe is a New York citizen and that the court has diversity jurisdiction.
Strain, proceeding pro se, filed an amended complaint, which supersedes his original complaint.
The court must screen the complaint for sufficiency because Strain is proceeding without prepaying fees and without counsel.
Strain also moved for early discovery to obtain Doe’s address, which Doe requested be kept confidential.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of factual allegations for state common law claim	Doe lied and caused illegal detention	Allegations are conclusory and lack detail	Dismissed for failure to state a claim
Appropriateness of early discovery	Needs to identify Doe for service	Disclosure not warranted, privacy/harassment concern	Denied as premature, privacy protected
Whether Doe can be sued under 42 U.S.C. § 1983	Doe acted under color of state law (argued in passing)	Not a public official/no state action	Section 1983 claim not viable
Confidentiality of Doe’s address	Seeks address for litigation	Requests confidentiality due to safety/privacy	Address kept in camera by court

Arnett v. Webster, 658 F.3d 742 (7th Cir. 2011) (complaints by pro se litigants must be liberally construed but still require factual detail)
Stanard v. Nygren, 658 F.3d 792 (7th Cir. 2011) (complaints must give fair notice and state plausible grounds for relief)
Warciak v. Subway Restaurants, Inc., 949 F.3d 354 (7th Cir. 2020) (reasonable inferences needed to find liability from complaint)
Wesbrook v. Ulrich, 90 F. Supp. 3d 803 (W.D. Wis. 2015) (failure to identify defamatory statements leads to dismissal)