



A Ninth Circuit panel reinstated a dismissed lawsuit brought by a Jane Doe who alleges she was trafficked through Nevada's legal, regulated brothel system from 2017 to 2022. A lower court had tossed the case after denying her request to proceed anonymously, but the appeals panel found the district court committed clear errors weighing her need for anonymity, the prejudice to defendants, and the public's interest in her identity.
Doe argues Nevada's prohibition on independent prostitution forces women into working under brothel operators she calls pimps, creating conditions for debt bondage, including confinement, mandatory fee-splitting and fines for rule violations. She contends this amounts to a 13th Amendment violation.
The panel rejected the lower court's reasoning that her fears of retaliation applied too broadly to the industry to justify anonymity, and clarified that public interest in assessing a plaintiff's credibility is a matter for a jury, not a reason to unmask her. The case now returns to proceed under her pseudonym.
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