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West v. King

United States District Court, District of Columbia
Nov 27, 2024
Civil Action 1:24-cv-02847 (UNA) (D.D.C. Nov. 27, 2024)

Opinion

Civil Action 1:24-cv-02847 (UNA)

11-27-2024

LEO WEST, Plaintiff, v. ANGUS KING, et al., Defendants.


MEMORANDUM OPINION

ANA C. REYES, United States District Judge

Currently before the Court is Plaintiff's pro se complaint (“Compl.”), ECF No. 1, and application for leave to proceed in forma pauperis (“IFP”), ECF No. 2. The Court grants Plaintiff's IFP application and, for the reasons explained below, it dismisses this matter without prejudice.

The complaint is difficult to follow. Plaintiff sues several United States senators and representatives, contending that the [sic] “government is not affair a affair is not a job an jobs.” See Compl. at 2-4. As best understood, Plaintiff goes on to broadly allege, without detail or context, that “false statements” have been made regarding veterans' access to housing. See id. at 4. He demands $1 million from each Defendant resulting from alleged “turmoil” at his current veteran's shelter, related to headaches caused by “fuss” and loud “voices.” See id.

First, pro se litigants must comply with the Rules of Civil Procedure. Jarrell v. Tisch, 656 F.Supp. 237, 239 (D.D.C. 1987). Federal Rule of Civil Procedure 8(a) requires a complaint to contain “(1) a short and plain statement of the grounds for the court's jurisdiction [and] . . . (2) a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed.R.Civ.P. 8(a); see Ashcroft v. Iqbal, 556 U.S. 662, 678-79 (2009). The Rule 8 standard ensures that defendants receive fair notice of the claim being asserted so that they can prepare a responsive answer and an adequate defense. Brown v. Califano, 75 F.R.D. 497, 498 (D.D.C. 1977). Here, as presented, neither the Court nor the Defendants can reasonably be expected to identify Plaintiff's claims, and the allegations fall well short of stating a plausible claim.

Second, even if his claims could be understood, Plaintiff fails to establish subject-matter jurisdiction, see Fed.R.Civ.P. 12(h)(3), citing only to 18 U.S.C. § 1001, see Compl. at 3, a criminal statute that “does not create a private cause of action,” Lee v. United States Agency for Int'l Develop., 859 F.3d 74, 78 (D.C. Cir. 2017) (per curiam); see Prunte v. Universal Music Group, 484 F.Supp.2d 32, 42 (D.D.C. 2007) (“[The] Supreme Court has refused to imply a private right of action in a bare criminal statute.”) (citation and internal quotation marks omitted); Rockefeller v. U.S. Court of Appeals for the Tenth Circuit, 248 F.Supp.2d 17, 20 (D.D.C. 2003) (same) (collecting cases).

For these reasons, this case is dismissed without prejudice. A separate Order accompanies this Memorandum Opinion.


Summaries of

West v. King

United States District Court, District of Columbia
Nov 27, 2024
Civil Action 1:24-cv-02847 (UNA) (D.D.C. Nov. 27, 2024)
Case details for

West v. King

Case Details

Full title:LEO WEST, Plaintiff, v. ANGUS KING, et al., Defendants.

Court:United States District Court, District of Columbia

Date published: Nov 27, 2024

Citations

Civil Action 1:24-cv-02847 (UNA) (D.D.C. Nov. 27, 2024)