LIAHG v. L'AMBASSADE DE FRANCE AUX USA

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
JULIETTE YAXI LIANG,
Plaintiff,
v.
L'AMBASSADE DE FRANCE AUX USA,
Defendant.
Civil Action No. 26-158 (RDM)
MEMORANDUM OPINION AND ORDER
This matter comes before the Court on review of Plaintiff’s pro se civil complaint, Dkt. 1
(Compl.). For the following reasons, the Court will dismiss the complaint without prejudice.
A pro se litigant’s pleadings are held to less stringent standards than the standard applied
to formal pleadings drafted by lawyers. See Haines v. Kerner, 404 U.S. 519, 520 (1972). Even
pro se litigants, however, must comply with the Federal Rules of Civil Procedure. Jarrell v.
Tisch, 656 F. Supp. 237, 239 (D.D.C. 1987). Rule 8 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).
The purpose of the minimum standard of Rule 8 is to give fair notice to the defendants of the
claim being asserted, sufficient to prepare a responsive answer, to prepare an adequate defense
and to determine whether the doctrine of res judicata applies. Brown v. Califano, 75 F.R.D. 497,
498 (D.D.C. 1977).
Plaintiff’s complaint fails to comply with the minimal pleading standard established by
Rule 8. The complaint purports to invoke the Court’s federal question jurisdiction under 28
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U.S.C. § 1331, but it does not identify a specific statute to serve as the basis for the claim.
Instead, the complaint merely lists a series of titles (but not sections) of the U.S. Code, without
reference to any individual provision or explanation of how those varied titles relate to the claims
at issue. Dkt. 1 at 3 (Compl.). In the “Statement of Claim” portion of the complaint, Plaintiff
includes general allegations that are difficult to parse, but which appear to concern alleged
misfeasance by Chinese spies and the loss of a French ID. Id. at 4 (Compl.). Those allegations
are too vague and conclusory to identify a basis for this Court to exercise jurisdiction over the
matter, to state any discernible legal claims, or to put a defendant on reasonable notice of the
basis of the claims against them. Moreover, to the degree that Plaintiff intends to assert a
sweeping conspiracy involving Chinese espionage, sex trafficking, and the French Embassy in
Washington, D.C., such “essentially fictitious” claims “that allege ‘bizarre conspiracy theories’”
are an insufficient basis to invoke this Court’s subject matter jurisdiction, and merit dismissal
under Federal Rule 12(b)(1) as well as Rule 8. Curran v. Holder, 626 F. Supp. 2d 30, 33
(D.D.C. 2009) (quoting Best v. Kelly, 39 F.3d 328, 330 (D.C. Cir. 1994)).
The Court will, therefore, dismiss Plaintiff’s complaint without prejudice for lack of
jurisdiction or, in the alternative, for failure to state a claim.
SO ORDERED.
/s/ Randolph D. Moss
RANDOLPH D. MOSS
United States District Judge
Date: March 2, 2026
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