Seventh Circuit bars anonymity
The Seventh Circuit ruled that plaintiffs bringing Title IX suits over alleged wrongful discipline cannot proceed anonymously, overturning a common practice in other courts. (reason.com)
A federal appeals court in Chicago said students who sue over campus sex-misconduct discipline usually must use their real names, not “John Doe.” (caselaw.findlaw.com) The United States Court of Appeals for the Seventh Circuit issued the ruling on April 13, 2026, in *Doe v. University of Southern Indiana*, No. 24-2245. Judge David Hamilton wrote the opinion, joined by Chief Judge Michael Brennan and Judge Amy St. Eve. (caselaw.findlaw.com) The plaintiff was accused of sexual assault during the 2020–21 school year, found responsible by a university panel, and suspended for three semesters in 2021. He sued the University of Southern Indiana and others, alleging sex discrimination under Title IX, due-process violations, and intentional infliction of emotional distress. (caselaw.findlaw.com) Title IX is the 1972 federal law that bars sex discrimination by schools that receive federal money. In these lawsuits, students disciplined for sexual misconduct often argue that colleges used unfair procedures or treated male students differently. (caselaw.findlaw.com) The Seventh Circuit said federal court starts from the opposite presumption: adult litigants are named in public, and Federal Rule of Civil Procedure 10(a) says a complaint “must name all the parties.” The panel said that rule does not create a Title IX exception. (law.cornell.edu, caselaw.findlaw.com) The court said anonymity can still be allowed in unusual cases, including concrete risks of physical harm or retaliation, but not for general fears of embarrassment or reputational damage. The panel said the plaintiff’s evidence of threats was old and did not show a current danger. (caselaw.findlaw.com, theindianalawyer.com) That holding extends a line the same court built in 2024. In *Doe v. Trustees of Indiana University* on April 26, 2024, and *Doe v. Loyola University Chicago* on May 3, 2024, the Seventh Circuit also rejected pseudonyms in Title IX wrongful-discipline cases. (caselaw.findlaw.com, caselaw.findlaw.com) The Southern Indiana case adds a wrinkle on the underlying discipline fight. The opinion says discovery later turned up internal memoranda that arguably showed the accused student’s story had stayed consistent and the complainant’s had not, even though the hearing panel relied on the opposite view. (caselaw.findlaw.com, reason.com) Even so, the anonymity question came first. The panel affirmed the district court’s refusal to let the plaintiff proceed as “John Doe,” reinforcing that in the Seventh Circuit, these cases will usually move forward in public under a plaintiff’s real name. (caselaw.findlaw.com)
