Tory Bowen, who is fighting to allow use of words like "rape" and "victim" in court, must prove to a federal judge by Tuesday that her lawsuit against a state judge was not frivolous.

"I have serious reservations about whether this action was commenced for the improper purpose of forcing Judge Cheuvront to recuse himself ... or for the improper purpose of generating pretrial publicity," U.S. District Judge Richard Kopf of Lincoln wrote in his order.

Kopf warned the 24-year-old Bowen and her attorneys that "sanctions may be imposed for failure to show cause." The sanctions could include dismissal of the case, fines or "such other sanctions as the court deems proper."

Ms. Bowen said in her complaint filed September 6 that Cheuvront, a Lancaster County district judge, violated her free speech rights by barring words including "rape," "victim" and "assailant" from the trial of Pamir Safi.

Safi, 34, was charged with first-degree sexual assault stemming from an encounter between Bowen and Safi at his apartment on Oct. 31, 2004. Safi says he and Bowen had consensual sex.

Bowen, a former student at the University of Nebraska-Lincoln who lives in Washington, D.C., says she was too intoxicated to give consent and that Safi knew it.

Kopf said in his order, "There is something profoundly disturbing about the notion that a federal judge has the power to tell a state judge how to do his job, particularly when that state judge is presumably trying to do nothing more than protect the rights of a citizen who may have been wrongly accused of rape."

Kopf also expressed his doubts about whether the lawsuit "has any legal basis whatsoever."

"For example," he said, "I cannot find any precedent for a suit of this kind."

That, said Bowen's attorney Wendy Murphy of Boston, is precisely the point, because she couldn't find any guidance either.