Ninth Circuit Revives Sex Trafficking Suit, Upholds Plaintiff Anonymity

The Ninth Circuit reinstated a sex trafficking suit, allowing plaintiff anonymity.

On October 6, 2026, the Ninth Circuit Court of Appeals reinstated a sex trafficking lawsuit brought by Jane Doe against several Nevada brothels, overturning a lower court's dismissal that had hinged on Doe's desire to maintain anonymity. The appellate panel ruled that the district court had abused its discretion by dismissing the case based on Doe’s anonymity alone, noting the district court failed to properly balance the competing interests of plaintiff privacy, potential prejudice to defendants, and the public's right to open judicial proceedings.

Jane Doe's complaint alleges she was trafficked and exploited from 2017 through 2022 within Nevada’s regulated brothel system. She contends that Nevada's prohibition of independent prostitution forces sex work under the control of third parties she refers to as pimps, leading to systematic exploitation within a legalized framework.

The court emphasized the importance of recognizing the need for plaintiff anonymity in cases like this. "The District Court committed a clear error in judgment in the analysis that it undertook to weigh those three factors," the panel stated. It further noted, "the fact that Doe’s assertions may apply broadly to others in the industry does not necessarily mean that Doe lacks a need for anonymity for those same reasons." The panel concluded that the lower court gave insufficient weight to Doe’s privacy concerns.

The appellate panel presiding over this decision included U.S. Circuit Judges Mark Bennett and Gabriel Sanchez along with U.S. District Judge John Holcomb sitting by designation. This ruling could affect future sex trafficking litigation and other cases where plaintiffs seek to protect their identities while pursuing claims.