MURRAY v. UNITED STATES OF AMERICA et al

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
SARA MURRAY,
Plaintiff,
v.
UNITED STATES OF AMERICA, et al.,
Defendants.
Civil Action No. 26-0345 (UNA)
MEMORANDUM OPINION
Complaints filed by pro se litigants are held to “less stringent standards” than those applied
to 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 the relief the pleader seeks. Fed. R. Civ. P. 8(a). This “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) (quoting Bell Atl. Corp. v. Twombly, 550
U.S. 544, 555 (2007)). This ensures the defendants have “notice of what the claim is and the
grounds upon which it rests.” Twombly, 550 U.S. at 555 (cleaned up).
Plaintiff’s complaint fails to give minimum notice of any cognizable claim, whether under
42 U.S.C. § 1983 or RICO, against any of the myriad defendants, among whom are federal and
state judges, court employees, members of Congress, assorted individuals, and the United States
of America. Its vague and conclusory allegations of wrongdoing are insufficient to provide “notice
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of what the claim is and the grounds upon which it rests.” Twombly, 550 U.S. at 555 (cleaned up);
see also 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)
(explaining that “a complaint that contains an untidy assortment of claims that are neither plainly
nor concisely stated” does not “comport with the standards of Rule 8”). Neither of plaintiff’s
proposed amended complaints (ECF Nos. 5-1 and 13-1) clarifies the nature of plaintiff’s purported
legal claims or the alleged facts supporting them.
Plaintiff is granted leave to proceed in forma pauperis and to use her Address
Confidentiality Program address. Because the complaint fails to comply with Rule 8(a), it will be
dismissed without prejudice, and plaintiff’s remaining motions will be denied without prejudice
as moot. An Order is issued separately.
/s/
RUDOLPH CONTRERAS
United States District Judge
Date: April 27, 2026
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