The First Amendment Coalition is representing Holly McDede, a freelance reporter, in the matter of Doe v. Mill Valley School District, a lawsuit that seeks to prevent the release of documents covered by the California Public Records Act (“CPRA”), also known as a “reverse-CPRA” case. McDede covers sexual misconduct in schools, and has previously written about other school employees’ misconduct.
On June 7, 2024, McDede sought public records from Mill Valley School District as part of an ongoing investigation into staff misconduct in various districts. On June 28, 2024, in response to a letter from the district, McDede updated the request to seek “public records related to claims of sexual harassment, sexual assault, or boundary crossing or grooming behavior made regarding teachers or other school employees” as well as “claims of sexual harassment, sexual assault, or grooming made to the California Commission on Teacher Credentialing.”
The district was then prepared to release certain records about the conduct of a former employee who resigned during an investigation into his behavior. However, the former employee, suing anonymously as John Doe, filed suit, arguing that disclosure would violate his right to privacy.
The court issued a temporary restraining order against disclosure and scheduled a hearing on November 6, 2024, to decide whether to grant a preliminary injunction. Both McDede and the district oppose the preliminary injunction on the ground that the allegations against Doe were both substantial and well founded and therefore the public’s interest in disclosure outweighs his alleged privacy interests.
After initially granting a preliminary injunction against disclosure, the court heard further briefing and argument and issued a final ruling on March 17, 2025 allowing the district to disclose certain records that identified Doe’s true name. No party appealed that ruling.
McDede and Doe then disputed whether certain court records should be sealed and whether the order allowing Doe to sue anonymously should be vacated. The trial court denied Doe’s motion to seal previously public records, but it also denied McDede’s motion to vacate the anonymity order.
After McDede appealed the latter denial, McDede and Doe agreed to a settlement under which the appeal was dismissed, Doe filed a declaration in the trial court stating his true name is Jeremy Scott Packman, and the trial court vacated the order allowing him to sue anonymously.
Legal Documents
- Stipulation and Order Vacating Order Allowing Plaintiff to Sue Anonymously (3/17/2026)
- Declaration Stating John Doe’s True Name (3/16/2026)
- Order on Motion to Unseal (9/11/2025)
- Doe’s Opposition to McDede’s Motion to Unseal (8/7/2025)
- Order Denying Doe’s Motion to Seal (7/11/2025)
- Doe Reply in Support of Motion to Seal (7/1/2025)
- McDede Opposition to Doe’s Motion to Seal (6/25/2025)
- McDede Motion to Unseal (5/21/2025)
- McDede Motion to Strike Plaintiff’s Costs (4/28/2025)
- Doe Motion to Partially Seal Court Records (4/8/2025)
- Order on Motion for Judgement (3/17/2025)
- Doe Reply in Support of Motion for Judgement (2/11/2025)
- McDede Opposition to Motion for Judgement (2/5/2025)
- Doe Motion for Judgement (1/22/2025)
- McDede Opposition to Preliminary Injunction (10/23/2024)
- Declaration of Holly McDede in Opposition to Preliminary Injunction (10/23/2024)
- Doe Motion for Preliminary Injunction (10/9/2024)
- Mill Valley School District Opposition to Preliminary Injunction (9/17/2024)
- Doe Complaint (9/6/2024)