Supreme Court Report

Supreme Court of the United States · Official docket →

John Doe v. Second Judicial District Court of Nevada, Washoe County, et al.

Paid petition · Supreme Court of Nevada, No. 89277 · judgment April 9, 2025


Certiorari denied · October 6, 2025
Pre-decision estimate: 6% cert probability (95% interval 4%–10%)

Before the decision, modestly above the 4.1% base rate. The model weighted this up for a petition filed soon after the judgment below and counsel who has filed here before.

Question presented

John Doe conducted an anonymous investigation of public figures based on concerns about corruption. Two elected officials, including the Mayor of Reno, the target of the investigation, sought to use litigation to unmask John Doe. The Nevada Supreme Court refused to apply the First Amendment to the investigation, declaring that the speech preparations were “non expressive” and “not subject to First Amendment protection.” The question presented is: Are speech preparatory investigations expressive and subject to First Amendment protection?

Counsel of record

For petitioner
Michael Lee Francisco
First & Fourteenth PLLC

For respondent
Adam Dmitri Hosmer-Henner
McDonald Carano LLP

Case

Subject area
First Amendment (estimated from the questions presented, in the Supreme Court Database’s categories)

Conference history
Distributed for 1 conference

Order
Order list, October 6, 2025 · Certiorari denied

Proceedings

  1. Oct 06 2025
    Petition DENIED.
  2. Jun 25 2025
    DISTRIBUTED for Conference of 9/29/2025.
  3. Jun 16 2025
    Waiver of right of respondent Real Parties in Interest Hillary Schieve and Vaughn Hartung to respond filed.
  4. May 19 2025
    Petition for a writ of certiorari filed. (Response due June 23, 2025)