Opinion
Civil Action 24-1917 (UNA)
07-24-2024
DASHON HINES, Plaintiff, v. DEPARTMENT OF TRANSPORTATION, Defendant.
MEMORANDUM OPINION
TREVOR N. McFADDEN UNITED STATES DISTRICT JUDGE
This matter is before the Court on initial review of plaintiff's pro se complaint, ECF No. 1, and application for leave to proceed in forma pauperis, ECF No. 2. The Court will grant the in forma pauperis application and dismiss the complaint without prejudice.
Complaints filed by pro se litigants are held to “less stringent standards” than those applied to pleadings drafted by lawyers. 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) (quotations omitted). In addition, Rule 8(d) states that “[e]ach allegation must be simple, concise, and direct.” FED. R. CIV. P. 8(d)(1). “Taken together, [those provisions] underscore the emphasis placed on clarity and brevity by the federal pleading rules.” Ciralsky v. CIA, 355 F.3d 661, 669 (D.C. Cir. 2004) (cleaned up). 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).
Plaintiff, a resident of Buffalo, New York, allegedly had an encounter on June 4, 2024, with an officer of the Cheektowaga, New York police force. See Compl. at 1. The officer allegedly “arrested the Plaintiff in violation of Title VI of the Civil Rights Act of 1964.” Id. The New York State Division of Human Rights dismissed plaintiff's complaint against the Town of Cheektowaga for lack of jurisdiction. See Compl., Ex. (ECF No. 1-1 at 2-3).
As drafted, the complaint fails to meet the minimal pleading standard set forth in Rule 8(a). For starters, plaintiff fails to identify a basis for this Court's jurisdiction. And what few factual allegations there are fail to put the United States Department of Transportation on notice of a claim against it, particularly where plaintiff's claim arises from his arrest by a Cheektowaga, New York, police officer. Lastly, plaintiff does not demand any form of relief. The Court, therefore, will dismiss the complaint without prejudice. An Order is issued separately.