Case: Doe 1 v. Patel

1:26-cv-00959 | U.S. District Court for the District of District of Columbia

Filed Date: March 19, 2026

Case Ongoing

Clearinghouse coding complete

Case Summary

This case challenges the Trump administration's employment termination of Federal Bureau of Investigation (FBI) agents who participated in the investigation that led to the federal prosecution of Donald Trump for efforts to overturn the 2020 presidential election. Two former FBI Special Agents, John Doe 1 and John Doe 2, filed suit in the U.S. District Court for the District of Columbia on March 19, 2026, alleging that they were terminated in retaliation for their involvement in Arctic Frost, a…

Two former FBI Special Agents, John Doe 1 and John Doe 2, filed suit in the U.S. District Court for the District of Columbia on March 19, 2026, alleging that they were terminated in retaliation for their involvement in Arctic Frost, an FBI investigation into efforts to overturn the 2020 presidential election that ultimately led to the 2023 indictment of then-former President Donald J. Trump. Both plaintiffs, who had received exemplary performance ratings and had no disciplinary history, had played support and administrative roles in the Arctic Frost investigation; they were fired in late 2025: Doe 1 on October 31 and Doe 2 on November 4. According to the complaint, FBI Director Kash P. Patel terminated them without notice, investigation, or an opportunity to respond, citing alleged "poor judgment" and participation in the "political weaponization of the government," while agency records listed only "Removal under Article 2 USC" as the basis for their dismissal. The plaintiffs alleged that defendants, including Patel, Attorney General Pam J. Bondi, the FBI, and the Department of Justice, targeted Arctic Frost personnel based on perceived political opposition to President Trump, in violation of the First Amendment, and deprived them of protected property and liberty interests without due process, in violation of the Fifth Amendment. They are seeking declaratory and injunctive relief, reinstatement, correction of personnel records, attorneys' fees, and a name-clearing hearing.

The U.S. has requested a briefing schedule on its intended motion to dismiss the case that would conclude in mid-August 2026.

Summary Authors

Benjamin Glicksman (6/12/2026)

Jinan Abufarha (3/21/2026)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/72515336/parties/doe-1-v-patel/

Attorney for Plaintiff

Donovan, Margaret (District of Columbia)

Hanke, Brittany (District of Columbia)

Tulis, Elizabeth Murray (District of Columbia)

Attorney for Plaintiff

Donovan, Margaret (District of Columbia)

Hanke, Brittany (District of Columbia)

Tulis, Elizabeth Murray (District of Columbia)

Attorney Contact Information via CourtListener

Documents in the Clearinghouse

Documents in this case

1 1:26-cv-00959	Complaint	March 19, 2026	March 19, 2026 Complaint

show / hide documents

Docket

See docket on RECAP: https://www.courtlistener.com/docket/72515336/doe-1-v-patel/

Last updated July 22, 2026, 3:25 a.m.

ECF Number	Date	Description	Link
1	March 19, 2026	COMPLAINT against PAMELA J. BONDI, FEDERAL BUREAU OF INVESTIGATION, KASHYAP P. PATEL, U.S. DEPARTMENT OF JUSTICE ( Filing fee $ 405 receipt number ADCDC-12308663) filed by JOHN DOE 1, JOHN DOE 2. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Civil Cover Sheet, # 6 Summons to Kashyap P. Patel, # 7 Summons to FBI, # 8 Summons to Pamela J. Bondi, # 9 Summons to DOJ, # 10 Summons to USAO-DC)(Tulis, Elizabeth) (Entered: 03/19/2026) 1 Exhibit A View on PACER 2 Exhibit B View on PACER 3 Exhibit C View on PACER 4 Exhibit D View on PACER 5 Civil Cover Sheet View on PACER 6 Summons to Kashyap P. Patel View on PACER 7 Summons to FBI View on PACER 8 Summons to Pamela J. Bondi View on PACER 9 Summons to DOJ View on PACER 10 Summons to USAO-DC View on PACER	Clearinghouse
2	March 19, 2026	NOTICE of Appearance by Margaret Donovan on behalf of All Plaintiffs (Donovan, Margaret) (Entered: 03/19/2026)	RECAP
3	March 19, 2026	SEALED MOTION for Leave to Proceed Under Pseudonym by JOHN DOE 1, JOHN DOE 2. (Attachments: # 1 Exhibit (Filed Under Seal), # 2 Text of Proposed Order)(Donovan, Margaret) Modified event on 3/20/2026 (znmw). (Entered: 03/19/2026) 1 Exhibit (Filed Under Seal) View on PACER 2 Text of Proposed Order View on PACER	RECAP
4	March 19, 2026	SEALED DOCUMENT filed by JOHN DOE 1, JOHN DOE 2 re 1 Complaint, (This document is SEALED and only available to authorized persons.)(Donovan, Margaret) (Entered: 03/19/2026)	RECAP
5	March 19, 2026	SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JOHN DOE 1, JOHN DOE 2 (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit (Exhibit A), # 2 Text of Proposed Order)(Donovan, Margaret) (Entered: 03/19/2026)	RECAP
6	March 26, 2026	MEMORANDUM OPINION AND ORDER: The Court ORDERS that: 1) Plaintiffs' 3 Motion to Proceed Under Pseudonyms is GRANTED, subject to any further consideration by the United States District Judge to whom this case is randomly assigned; 2) All parties shall use the pseudonyms listed in the Complaint in all documents filed in this action; and 3) Within fourteen days of this Order, Plaintiffs shall file: i) A pseudonymous version of their 3 Motion on the public docket; and ii) A sealed declaration containing their real names and residential addresses. Signed by Chief Judge James E. Boasberg on March 26, 2026. (lcjeb4) (Entered: 03/26/2026)	RECAP
7	March 27, 2026	SUMMONS (5) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(znmw) (Entered: 03/27/2026)	RECAP
8	March 27, 2026	MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Brittany Hanke, Filing fee $ 100, receipt number ADCDC-12325593. Fee Status: Fee Paid. by JOHN DOE 1, JOHN DOE 2. (Attachments: # 1 Exhibit A - Declaration of Brittany Hanke, # 2 Exhibit B - Certificate of Good Standing, # 3 Text of Proposed Order)(Tulis, Elizabeth) (Entered: 03/27/2026)	RECAP
9	March 27, 2026	ERRATA - Corrected Text of Proposed Order by JOHN DOE 1, JOHN DOE 2 re 8 Motion for Leave to Appear Pro Hac Vice,. (Tulis, Elizabeth) (Entered: 03/27/2026)	RECAP
	March 27, 2026	Case Assigned/Reassigned
	March 27, 2026	Case Assigned to Judge Jia M. Cobb. (znmw)
11	March 30, 2026	SEALED DOCUMENT (Exhibit A) filed by JOHN DOE 1, JOHN DOE 2. re 3 Sealed Motion to Proceed Under Pseudonym. (This document is SEALED and only available to authorized persons.)(znmw) (Entered: 04/01/2026)	RECAP
	March 30, 2026	MINUTE ORDER granting 8 Motion for Leave to Appear Pro Hac Vice: Attorney Brittany Hanke is hereby admitted pro hac vice to appear in this matter. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Judge Jia M. Cobb on March 30, 2026. (lcjmc3)
	March 30, 2026	Order on Motion for Leave to Appear Pro Hac Vice
	March 30, 2026	Order on Sealed Motion for Leave to File Document Under Seal
	March 30, 2026	ORDER granting 5 Sealed Motion for Leave to File Document Under Seal. Signed by Judge Jia M. Cobb on 3/30/2026. (zed)
10	April 1, 2026	NOTICE of Appearance by Brittany Hanke on behalf of JOHN DOE 1, JOHN DOE 2 (Hanke, Brittany) (Entered: 04/01/2026)	RECAP
12	April 6, 2026	RESPONSE TO ORDER OF THE COURT re 6 Order,,, Memorandum & Opinion,, filed by JOHN DOE 1, JOHN DOE 2. (Attachments: # 1 Exhibit ECF No. 3 (unsealed))(Donovan, Margaret) (Entered: 04/06/2026) 1 Exhibit ECF No. 3 (unsealed) View on RECAP	RECAP
13	April 6, 2026	SEALED DOCUMENT filed by JOHN DOE 1, JOHN DOE 2 re 6 Order,,, Memorandum & Opinion,, (This document is SEALED and only available to authorized persons.)(Donovan, Margaret) (Entered: 04/06/2026)	RECAP
14	April 15, 2026	RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 3/27/2026. Answer due for ALL FEDERAL DEFENDANTS by 5/26/2026. (Attachments: # 1 Exhibit Proof of Service - USAO-DC)(Donovan, Margaret) (Entered: 04/15/2026)	RECAP
15	May 26, 2026	NOTICE of Appearance by Isaac Belfer on behalf of All Defendants (Belfer, Isaac) (Entered: 05/26/2026)	RECAP
16	May 26, 2026	Unopposed MOTION to Stay re 14 Summons Returned Executed as to US Attorney, Defendants Unopposed Motion to Stay Their Deadline to Respond to the Complaint Pending the Entry of a Briefing Schedule for Their Motion to Dismiss by PAMELA J. BONDI, FEDERAL BUREAU OF INVESTIGATION, KASHYAP P. PATEL, U.S. DEPARTMENT OF JUSTICE. (Attachments: # 1 Text of Proposed Order)(Belfer, Isaac) (Entered: 05/26/2026) 1 Text of Proposed Order View on PACER	RECAP
	May 28, 2026	MINUTE ORDER granting 16 Motion to Stay: Having considered the motion, and for good cause shown, the Court GRANTS the motion. Defendants' deadline to respond to the complaint is stayed pending the entry of a briefing schedule. The parties are further ORDERED to file a joint status report with their proposed briefing schedule by June 11, 2026. Signed by Judge Jia M. Cobb on May 28, 2026. (lcjmc3)
	May 28, 2026	Order on Motion to Stay AND Set/Reset Deadlines
17	June 10, 2026	Joint STATUS REPORT by PAMELA J. BONDI, FEDERAL BUREAU OF INVESTIGATION, KASHYAP P. PATEL, U.S. DEPARTMENT OF JUSTICE. (Belfer, Isaac) (Entered: 06/10/2026)	RECAP