Procedure-Pseudonyms

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7^th Circuit Court of Appeals

Case Name: John Doe v. Loyola University Chicago

Case No.: 22-2925

Officials: Easterbrook, Rovner, and St. Eve, Circuit Judges.

Focus: Procedure-Pseudonyms

John Doe, a student faced expulsion from Loyola University Chicago following the university’s determination that he had engaged in non-consensual sexual activity with another student, Jane Roe. Doe filed a lawsuit against the university, citing Title IX of the Education Amendments Act of 1972 and Illinois contract law, alleging gender discrimination against men.

Initially, the Northern District of Illinois ruled in favor of Loyola, granting summary judgment. On appeal, the Seventh Circuit raised concerns regarding the use of pseudonyms by the involved parties and the mootness of the case, as Doe had already graduated from another university, rendering the typical remedy of readmission inapplicable.

Consequently, the Seventh Circuit remanded the case back to the district court to address these issues. The court pondered whether compensatory damages were feasible for Doe and, if not, whether the case was justiciable. Additionally, it questioned the use of pseudonyms, emphasizing that while anonymity might be customary in Title IX suits, it necessitates justification in each instance. The court stressed the public’s entitlement to know who utilizes the legal system, asserting that the desire to conceal embarrassing information doesn’t warrant anonymity. Moreover, the court expressed apprehensions about whether disclosing Doe’s identity would indirectly expose Roe’s identity. Consequently, the court deemed it imperative for the district court to tackle these concerns.

Remanded.

Decided 05/03/24

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