Opinion
Civil Action 22-2426 (UNA)
09-20-2022
CURTIS L. DOWNING, Plaintiff, v. STEVE SISOLAK et al., Governor of Nevada, Defendants.
MEMORANDUM OPINION
JIA M. COBB, United States District Judge.
This action, brought pro se, is before the Court on review of Plaintiff's Civil Rights Complaint, ECF No. 1, and application to proceed in forma pauperis, ECF No. 2. The Court will grant the application and dismiss the complaint.
Complaints filed by pro se litigants are held to less stringent standards than those applied to formal pleadings drafted by lawyers. See Haines v. Kerner, 404 U.S. 519, 520 (1972). Still, pro se litigants must comply with the Federal Rules of Civil Procedure. Jarrell v. Tisch, 656 F.Supp. 237, 239 (D.D.C. 1987). Rule 8(a) 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). It “does not require detailed factual allegations, but it demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (internal quotation marks and citation omitted).
The Rule 8 standard ensures that defendants receive fair notice of the claim being asserted so that they can prepare a responsive answer, mount an adequate defense, and determine whether the doctrine of res judicata applies. See Brown v. Califano, 75 F.R.D. 497, 498 (D.D.C. 1977). The standard also assists the court in determining whether it has jurisdiction over the subject matter.
Plaintiff, a Nevada state prisoner, has lodged a 473-page rambling complaint against the Governor of Nevada and “Jon and/or Jane Does, 1-100.” Compl. Caption. The complaint is neither short nor plain and fails sorely to provide adequate notice of a claim. See Jiggetts v. District of Columbia, 319 F.R.D. 408, 413 (D.D.C. 2017), aff'd sub nom. Cooper v. District of Columbia, No. 17-7021, 2017 WL 5664737 (D.C. Cir. Nov. 1, 2017) (a complaint that is “rambling, disjointed, incoherent, or full of irrelevant and confusing material will patently fail [Rule 8(a)'s] standard,” as will one containing “an untidy assortment of claims that are neither plainly nor concisely stated”) (internal quotation marks and citations omitted)). Consequently, it will be dismissed without prejudice.
A separate order accompanies this Memorandum Opinion.