SCHIFF v. TRUMP et al

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
GRAHAM SCHIFF,
Plaintiff,
v.
DONALD TRUMP, et al.,
Defendants.
Civil Action No. 25 - 4571 (UNA)
MEMORANDUM OPINION
This matter is before the court on Plaintiff Graham Schiff’s application to proceed in forma
pauperis, ECF No. 2, and pro se complaint, ECF No. 1. For the reasons explained below, the court
will grant Mr. Schiff’s application and dismiss the complaint without prejudice.
“Federal courts are courts of limited jurisdiction,” and it is generally presumed that “a cause
lies outside [of] this limited jurisdiction.” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S.
375, 377 (1994). Accordingly, “a district court may dismiss a complaint sua sponte prior to service
on the defendants pursuant to Fed. R. Civ. P. 12(h)(3) when, as here, it is evident that the court
lacks subject-matter jurisdiction.” Evans v. Suter, No. 09-5242, 2010 WL 1632902, at *1
(D.C. Cir. Apr. 2, 2010) (per curiam); see Fed. R. Civ. P. 12(h)(3) (“If the court determines at any
time that it lacks subject-matter jurisdiction, the court must dismiss the action.”). “A dispute does
not fall within the subject-matter jurisdiction of federal courts unless it qualifies as a ‘case’ or
‘controversy’ within the meaning of article III, and it cannot so qualify unless the plaintiff has
suffered ‘injury in fact.’” Ananiev v. Freitas, 37 F. Supp. 3d 297, 305 (D.D.C. 2014) (quoting
Nat’l Ass’n of Recycling Indus., Inc. v. Sec’y of Com., 494 F. Supp. 158, 160 (D.D.C. 1980)).
Case 1:25-cv-04571-UNA Document 4 Filed 02/17/26 Page 1 of 3

2
Article III standing is comprised of three elements: “(1) the plaintiff must have suffered an ‘injury
in fact’ that is ‘concrete and particularized’ and ‘actual or imminent, not conjectural or
hypothetical’; (2) there must exist ‘a causal connection between the injury and the conduct
complained of’; and (3) it must be ‘likely, as opposed to merely speculative, that the injury will be
redressed by a favorable decision.’” Friends of Animals v. Jewell, 828 F.3d 989, 991-92 (D.C. Cir.
2016) (quoting Lujan v. Defs. of Wildlife, 504 U.S. 555, 560-61 (1992)).
Mr. Schiff, a United States citizen, objects to the President’s “assertion of unilateral
executive power” with respect to Greenland. ECF No. 1, at 9.1 He alleges that “Defendants have
publicly suggested or supported the creation or use of a role styled as ‘Greenland Special Envoy’”
without a “statutory basis, congressional authorization, [or] grounding in any treaty or international
agreement.” Id. (emphases omitted). In Mr. Schiff’s view, such a Special Envoy would “advance
unilateral executive aims—by inducement, pressure, or implication—outside constitutional
channels, with effects on Greenland’s sovereignty and Denmark’s territorial integrity.” Id.
(emphasis omitted). Among other relief, he seeks a declaration that any future executive action
“purporting to annex, coerce, induce, imply, or otherwise affect Greenland’s sovereignty is void
ab initio.” Id. at 12 (emphasis omitted).
Mr. Schiff fails to sufficiently allege that he has sustained, or is likely to sustain, injury
resulting from Defendants’ actions. Mr. Schiff may not pursue the interests of the citizens of
Greenland, and he may not bring this action in a representative capacity “because Greenlanders
cannot themselves ask this Court” for relief. ECF No. 1, at 10; see Doe v. United States,
No. 25-CV-1229, 2025 WL 1895607, at *1 (D.D.C. July 7, 2025) (stating that, “[a]s a general rule
1 When citing ECF No. 1, the court refers to the CM/ECF-generated numbers at the top of each
page rather than any internal pagination.
Case 1:25-cv-04571-UNA Document 4 Filed 02/17/26 Page 2 of 3

3
applicable here, a pro se litigant can represent only himself in federal court” (quoting Cannady v.
Missouri, No. 15-CV-73, 2015 WL 358236, at *1 (D.D.C. Jan. 13, 2015))); see also 28 U.S.C.
§ 1654 (providing that “parties may plead and conduct their own cases personally or by counsel”).
Mr. Schiff’s demand that Defendants act within the scope of their constitutional authority is also
not unique to him. A plaintiff “must demonstrate ‘a personal stake in the outcome of the
controversy’” to have Article III standing. Hall v. D.C. Bd. of Elections, 141 F.4th 200, 205
(D.C. Cir. 2025) (quoting Gill v. Whitford, 585 U.S. 48, 65 (2018)). A plaintiff like Mr. Schiff
who raises “a generally available grievance about government—claiming only harm to his and
every citizen’s interest in proper application of the Constitution and laws, and seeking relief that
no more directly and tangibly benefits him than it does the public at large—does not state an
Article III case or controversy.” Lujan, 504 U.S. at 573-74. Because Mr. Schiff fails to allege
facts sufficient to establish standing, this court lacks subject-matter jurisdiction to hear his claims.
Accordingly, the court will grant Mr. Schiff’s application to proceed in forma pauperis,
ECF No. 2, and dismiss the complaint without prejudice for lack of subject-matter jurisdiction,
ECF No. 1. A contemporaneous order will issue.
LOREN L. ALIKHAN
United States District Judge
Date: February 17, 2026
Case 1:25-cv-04571-UNA Document 4 Filed 02/17/26 Page 3 of 3