Doe v. University of Southern Indiana

In a case involving allegations of sex discrimination in education programs brought under Title IX of the Education Amendments Act, the Seventh Circuit considered the limited question of whether the plaintiff should be allowed to proceed under a John Doe pseudonym or whether he must proceed using his real name. The district court order that plaintiff litigate under his real name but stayed its order pending appeal. The Seventh Circuit affirmed, finding that the district court did not abuse its discretion by denying plaintiff the use of a pseudonym and declined to broaden the existing legal standard to protect a party from risks that publicity would harm mental health. The Seventh Court further kept the appeal under advisement to allow plaintiff the opportunity to dismiss the appeal to avoid public disclosure of his name. (BRENNAN and ST. EVE, concurring)