Jane Doe v. LAKE COUNTY SHERIFF and OFFICER MARKOYA

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted August 18, 2026*
Decided August 18, 2026
Before
MICHAEL B. BRENNAN, Chief Judge
AMY J. ST. EVE, Circuit Judge
JOHN Z. LEE, Circuit Judge
No. 25-2668
JANE DOE,
Plaintiff-Appellant,
v.
LAKE COUNTY SHERIFF and
OFFICER MARKOYA,
Defendants-Appellees.
Appeal from the United States District
Court for the Northern District of
Illinois, Eastern Division.
No. 25-cv-4815
Mary M. Rowland,
Judge.
O R D E R
This is an interlocutory appeal from the district court’s denial of Jane Doe’s
motion to proceed in her lawsuit under a pseudonym. The district court denied the
* The appellees were not served with process and are not participating in this
appeal. We have agreed to decide the case without oral argument because the brief and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

-- 1 of 2 --

No. 25-2668 Page 2
motion because she did not adequately justify her need for anonymity. We affirm and
remand for proceedings consistent with this order.
We accept the allegations in Doe’s complaint as true. See Doe v. Vill. of Deerfield,
819 F.3d 372, 374 (7th Cir. 2016). In 2023, Doe’s mother called the police after a dispute
broke out between Doe and her brother. An officer responded to the call and arrested
Doe in an aggressive manner, injuring her wrist. According to Doe, her mother had
called the police to seek a mental-health evaluation for Doe, not to lodge a criminal
complaint.
Doe sued the Lake County, Illinois, Sheriff and the arresting officer for
constitutional violations under 42 U.S.C. §§ 1983, 1985, 1986. She moved to proceed in
forma pauperis under a pseudonym, citing reputational harm that could result from
public disclosure of the case, which included allegations of domestic violence. The
district court granted Doe’s IFP motion, screened the complaint under 28 U.S.C.
§ 1915(e)(2), and allowed her to proceed only on her § 1983 claim of excessive force
against the individual officer. But the court declined to allow Doe to use a pseudonym
because the risk of reputational harm did not justify anonymity. If she wished to keep
her name a secret, the court advised, she needed to voluntarily dismiss her suit under
Federal Rule of Civil Procedure 41(a)(2) or her name would be added to the public
docket. Upon Doe’s request, the court stayed its decision pending her appeal.
In this interlocutory appeal, Doe challenges the district court’s denial of her
motion to proceed anonymously. This denial is immediately appealable as a collateral
order. Vill. of Deerfield, 819 F.3d at 376. Doe maintains that use of a pseudonym is
justified because disclosure of the alleged domestic violence would cause her
psychological, professional, and familial harm. But the court’s exercise of discretion
here was sound. Id. Adult litigants may proceed under a pseudonym only if exceptional
circumstances outweigh the public’s right to open judicial proceedings and the
prejudice to the opposing party. Id. at 376–77. As the court rightly explained, Doe’s
proffered concerns boil down to reputational harm, which does not justify anonymity.
See Doe v. Loyola Univ. Chi., 100 F.4th 910, 913 (7th Cir. 2024).
Because Doe may proceed with her excessive force claim against the officer
under her given name, we remand for proceedings consistent with this order. If Doe
chooses not to name herself, her complaint must be dismissed. See Doe v. Trs. of Ind.
Univ., 101 F.4th 485, 493 (7th Cir. 2024).
AFFIRMED and REMANDED

-- 2 of 2 --