Opinion
Civil Action 22-cv-1914 (UNA)
08-15-2022
KIMBERLY D. CROSSON, Plaintiff, v. THOMAS J. DONOVAN, et al., Defendants.
MEMORANDUM OPINION
FLORENCE Y. PAN, UNITED STATES DISTRICT JUDGE
This matter is before the Court on Plaintiff's application to proceed in forma pauperis [2], her pro se complaint [1], and a motion construed as one for a CM/ECF password [3]. The Court grants the application, denies the motion, and for the reasons stated below, dismisses the complaint without prejudice.
A pro se litigant's pleading is held to less stringent standards than would be applied to a formal pleading drafted by a lawyer. See Haines v. Kerner, 404 U.S. 519, 520 (1972). Even pro se litigants, however, must comply with the Federal Rules of Civil Procedure. Jarrell v. Tisch, 656 F.Supp. 237, 239 (D.D.C. 1987). Rule 8 of the Federal Rules of Civil Procedure requires that a complaint contain a short and plain statement of the grounds upon which the Court's jurisdiction depends, a short and plain statement of the claim showing that the pleader is entitled to relief, and a demand for judgment for the relief the pleader seeks. Fed.R.Civ.P. 8(a). The purpose of the minimum standard of Rule 8 is to give fair notice to the defendants of the claim being asserted, sufficient to prepare a responsive answer, to prepare an adequate defense, and to determine whether the doctrine of res judicata applies. Brown v. Califano, 75 F.R.D. 497, 498 (D.D.C. 1977).
As drafted, Plaintiff's complaint fails to meet the minimal pleading standard set forth in Rule 8(a). In the complaint, Plaintiff alleges violations of assorted federal statutes and constitutionally protected rights, without articulating an actual legal claim. Missing from the complaint is a statement of this Court's jurisdiction, and Plaintiff's demand for relief is vague at best. Furthermore, because all parties reside or conduct business in Vermont, and because the events giving rise to this action occurred in Vermont, it does not appear that the District of Columbia is the proper forum for adjudication of any of Plaintiff's claims. Accordingly, the Court is constrained to conclude that the complaint is insufficient as it is currently written.
An Order is issued separately.