Igo v. Clerk of the United States District Court for Massachusetts

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
John Igo
v. Case No. 26-CV-10997-SDE
Clerk of the United States
District Court for Massachusetts
ORDER
Plaintiff John Igo brings this action seeking an order
directing Defendant Clerk of the United States District Court
for the District of Massachusetts to review the policies and
local rules governing Central Violations Bureau (“CVB”)
violations and to “keep a file of ticket numbers and charges and
not leave it to out-of-state entities and report actions to the
District Judge overseeing CVB Magistrate Court.” Doc. No. 1
(Compl.) at 4. Mr. Igo’s complaint (Doc. No. 1) and
supplemental complaint (Doc. No. 4) are before the court for
preliminary review.1 For the following reasons, the court
determines that Mr. Igo has failed to demonstrate requisite
standing to bring his claims. Mr. Igo may amend his complaint
within 30 days to allege sufficient facts to demonstrate
standing. Otherwise, the court will recommend dismissal for
lack of subject matter jurisdiction.
1 The court also reviewed Mr. Igo’s Letter re Civil Cover
Sheet Notice (Doc. No. 3).
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Standard of Review
When a plaintiff is permitted to proceed without prepayment
of the filing fee, the court may conduct a preliminary review of
the complaint pursuant to 28 U.S.C. § 1915(e)(2). The statute
authorizes the court to dismiss any claims that are frivolous,
malicious, fail to state a claim upon which relief may be
granted, or seek monetary relief against a defendant who is
immune from such relief. 28 U.S.C. § 1915(e)(2). The court
also always maintains the responsibility to review its subject
matter jurisdiction and dismiss actions if it determines
jurisdiction is lacking. Fed. R. Civ. P. 12(h)(3).
Background
Mr. Igo alleges that, in February, the assistant clerk at
the United States District Court for the District of
Massachusetts told him there was no record of CVB files,
dockets, or calendars. Doc. No. 1 at 4. He also alleges that
Defendant “does not schedule a pretrial conference, accurate
notice of events to take place, filing of a written answer,
means to file reasonable discovery.” Id. Mr. Igo describes his
cause of action as “management of clerk’s office.” Doc. No. 1-1
at 1.
Discussion
The court reviews whether Mr. Igo has demonstrated standing
to bring this action because a lack of standing implicates the
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court’s subject matter jurisdiction. See Hochendoner v. Genzyme
Corp., 823 F.3d 724, 730 (1st Cir. 2016).
“For a plaintiff to get in the federal courthouse door and
obtain a judicial determination of what the governing law is,
the plaintiff cannot be a mere bystander, but instead must have
a ‘personal stake’ in the dispute.” Food and Drug Admin. v.
Alliance for Hippocratic Med., 602 U.S. 367, 379 (2024)
(“Article III requires a plaintiff to first answer a basic
question: ‘What’s it to you?’”). “The requirement that the
plaintiff possess a personal stake helps ensure that courts
decide litigants’ legal rights in specific cases, as Article III
requires, and that courts do not opine on legal issues in
response to citizens who might ‘roam the country in search of
governmental wrongdoing.’” Id. (quoting Valley Forge Christian
Coll. v. Am. United for Separation of Church and State, Inc.,
454 U.S. 464, 487 (1982)). “Standing also tends to assure that
the legal questions presented to the court will be resolved, not
in the ratified atmosphere of a debating society, but in a
concrete factual context conducive to a realistic appreciation
of the consequences of judicial action.” Id. (quotation
omitted). “Moreover, the standing doctrine serves to protect
the ‘autonomy’ of those who are most directly affected so that
they can decide whether and how to challenge the defendant’s
action.” Id. at 379–80 (quotation omitted).
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To protect those ideals, a plaintiff must demonstrate an
injury in fact. Id. at 381. The injury must be concrete and
particularized. Id. Federal courts cannot issue advisory
opinions about the law, “[n]or do federal courts operate as an
open forum for citizens to press general complaints about the
way in which government goes about its business.” Id. at 378–79
(quotation omitted). “A citizen may not sue based only on an
asserted right to have the Government act in accordance with the
law.” Id. “Nor may citizens sue merely because their legal
objection is accompanied by a strong moral, ideological, or
policy objection to a government action.” Id. As the United
States Supreme Court put it,
The injury in fact requirement prevents the federal
courts from becoming a vehicle for the vindication of
the value interests of concerned bystanders. An Article
III court is not a legislative assembly, a town square,
or a faculty lounge. Article III does not contemplate a
system where 330 million citizens can come to federal
court whenever they believe that the government is
acting contrary to the Constitution or other federal
law. Vindicating the public interest (including the
public interest in Government observance of the
Constitution and laws) is the function of Congress and
the Chief Executive.
Id. at 382 (citations omitted).
Mr. Igo seeks an order requiring Defendant to review the
policies and local rules related to CVB violations and to, in
essence, follow a particular organizational method for CVB
matters. He asserts that “CVB is de minimis, but the USDC is a
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community court and these cases are important to citizens, it is
in the interest of justice.” Doc. No. 1 at 4. Mr. Igo does not
allege that he is a party to a CVB matter in the district or any
other facts indicating that he has a personal particularized
interest in the organization of the CVB files. Rather, it
appears from Mr. Igo’s allegations that he seeks to vindicate
the public’s interest as a concerned citizen. For reasons
outlined above, that rationale does not confer standing.
Without a concrete and particularized injury, Mr. Igo has failed
to demonstrate the requisite standing to pursue his claim.
Absent standing, this court lacks subject matter jurisdiction.
Hochendoner, 823 F.3d at 730.
Conclusion
For the foregoing reasons, the court will permit Mr. Igo a
period of 30 days to amend his complaint to allege facts
demonstrating requisite standing to pursue his claims. Failure
to do so will result in a recommended dismissal.
So Ordered.
__________________________
Andrea K. Johnstone
United States Magistrate Judge
Sitting by Designation
April 6, 2026
cc: John Igo, pro se
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