GARLAND v. GOVERNMENT OF THE DISTRICT OF COLUMBIA

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
LEON GARLAND,
Plaintiff,
v.
GOVERNMENT OF THE DISTRICT OF
COLUMBIA,
Defendant.
Civil Action No. 26-00087 (AHA)
Memorandum Opinion
Leon Garland sues the District of Columbia alleging he was injured while working for the
District and seeking damages. ECF No. 1 at 4. On review of Garland’s complaint, the court
concludes it cannot be brought in federal court and dismisses for lack of subject matter jurisdiction.
To proceed in federal court, a plaintiff’s complaint must plausibly establish federal subject
matter jurisdiction. See Shuler v. United States, 531 F.3d 930, 932 (D.C. Cir. 2008). In considering
whether the complaint does so, the court must “assume the truth of all material factual allegations
in the complaint and ‘construe the complaint liberally, granting plaintiff the benefit of all
inferences that can be derived from the facts alleged,’ and upon such facts determine jurisdictional
questions.” Am. Nat’l Ins. Co. v. FDIC, 642 F.3d 1137, 1139 (D.C. Cir. 2011) (citations omitted).
Because Garland is proceeding pro se, the court is careful to give extra leeway, evaluating the
complaint “in light of all filings.” Ho v. Garland, 106 F.4th 47, 50 (D.C. Cir. 2024) (quotation
marks omitted) (quoting Brown v. Whole Foods Mkt. Grp., Inc., 789 F.3d 146, 152 (D.C. Cir.
2015)). However, “[i]f the court determines at any time that it lacks subject-matter jurisdiction, the
court must dismiss the action.” Fed. R. Civ. P. 12(h)(3).
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Garland appears to assert a personal injury claim against the District under D.C. law and
relies on diversity jurisdiction to bring it in federal court rather than in D.C. Superior Court.
However, the complaint does not plausibly establish diversity of citizenship. The diversity statute
gives federal courts jurisdiction over civil actions between citizens of different states where more
than $75,000 is in controversy. 28 U.S.C. § 1332(a)(1). Garland asserts diversity jurisdiction exists
because he is a Virginia citizen and the District is, well, in the District. ECF No. 1 at 3. But it is
well-established “the District is not subject to the diversity jurisdiction of the federal courts”
because it is not considered a “citizen” of a state. Long v. District of Columbia, 820 F.2d 409, 414
(D.C. Cir. 1987). Garland accordingly cannot establish diversity of citizenship on this basis.
Therefore, the court lacks subject matter jurisdiction over Garland’s complaint, although he can
likely sue in D.C. Superior Court.
For these reasons, the court dismisses Garland’s complaint without prejudice. A separate
order accompanies this memorandum opinion.
AMIR H. ALI
United States District Judge
Date: 	February 6, 2026
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