UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

JOHN DOE, individually, and on behalf of ) 

others similarly situated, ) 

 ) 

Plaintiff, ) 

) Case No. 20-cv-2531 

v. ) 

) Judge Sharon Johnson Coleman 

DONALD TRUMP, et al., ) 

) 

Defendant. ) 

ORDER 

 The Court, in its discretion, denies plaintiff’s motion to proceed under a pseudonym [36]. 

BACKGROUND 

 The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) mandated that 

every eligible American making under $75,000 a year individually and $150,000 jointly, would receive 

a certain amount of money due to the economic decline during the COVID-19 pandemic. The 

CARES Act, however, prohibits payments to individuals who do not have a social security number. 

Also, the CARES Act prohibits payments to individuals who jointly file their taxes with a spouse 

who does not have a social security number. See 26 U.S.C. § 6428 (d)(1). Plaintiff’s putative class 

action is one of four lawsuits in the United States federal courts challenging 26 U.S.C. § 6428. See

Amador v. Mnuchin, 1:20-cv-01102 (D. Md.); R.V. v. Mnuchin, 8:20-cv-01448 (D. Md.); Uzoegwu v. 

Mnuchin, 1:20-cv-03264 (S.D.N.Y.). 

LEGAL STANDARD 

Although district courts have the discretion to allow parties to proceed anonymously, 

“anonymous litigation runs contrary to the rights of the public to have open judicial proceedings.” 

Doe v. Village of Deerfield, 819 F.3d 372, 377 (7th Cir. 2016); see also Mueller v. Raemisch, 740 F.3d 1128, 

1135 (7th Cir. 2014) (“Secrecy in judicial proceedings, including concealment of parties’ names, is 

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disfavored.”). There is a presumption that parties’ identities are public information. Doe v. City of 

Chicago, 360 F.3d 667, 669 (7th Cir. 2004). To overcome this presumption, “a party must 

demonstrate ‘exceptional circumstances’ that outweigh both the public policy in favor of identified 

parties and the prejudice to the opposing party that would result from anonymity.” Deerfield, 819 

F.3d at 377; see also E.A. v. Gardner, 929 F.3d 922, 926 (7th Cir. 2019). “[A] party’s allegation of fear 

of retaliation ‘is often a compelling ground’ in favor of anonymity.” Deerfield, 819 F.3d at 377 

(citation omitted).

DISCUSSION 

In the present motion, plaintiff, on behalf of the class, asserts that using true names presents 

certain harms, including humiliation, harassment, and taunting by neighbors and co-workers due to 

the immigration issues involved. At the motion hearing, plaintiff explained that a putative class 

member’s spouse has ongoing immigration proceedings and is worried that using true names would 

negatively impact these proceedings. The Court understands the volatile nature of immigration 

issues in our country during these uncertain times. That said, the Court presumes the immigration 

judge will uphold his or her oath of office and properly enforce the laws of the United States. The 

Court further presumes, without contrary facts, that any official personnel involved in the referred 

to proceedings will act professionally. Thus, this argument alone does not establish “exceptional 

circumstances” under controlling Seventh Circuit law, let alone plaintiff’s generalized fear of 

humiliation and harassment

The Court further notes that in the other lawsuits challenging § 6428, only the plaintiffs in 

R.V. v. Mnuchin, 8:20-cv-01448 (D. Md.), are proceeding anonymously because they are minors. See

Fed. R. Civ. P. 5.2(a). Here, plaintiff has failed to give a sufficient explanation why the present 

lawsuit differs from the other two lawsuits where plaintiffs are proceeding under their true names. 

See Amador v. Mnuchin, 1:20-cv-01102 (D. Md.); Uzoegwu v. Mnuchin, 1:20-cv-03264 (S.D.N.Y.). 

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In the end, without more a particularized fear of retribution, plaintiff has failed to establish 

that proceeding anonymously outweighs the public policy in favor of identified parties and any 

prejudice defendants will suffer by defending this action without the identities of the plaintiffs. See 

Deerfield, 819 F.3d at 376-77 (“anonymous litigation runs contrary to the rights of the public to have 

open judicial proceedings and to know who is using court facilities and procedures funded by public 

taxes.”). The Court, in its discretion, denies plaintiff’s motion to proceed under a pseudonym.

IT IS SO ORDERED.

Date: 7/1/2020 

 Entered: _____________________________ 

 SHARON JOHNSON COLEMAN 

 United States District Court Judge 

Case: 1:20-cv-02531 Document #: 42 Filed: 07/01/20 Page 3 of 3 PageID #:351