In this case, plaintiffs sued Iran, its Islamic Revolutionary Guard Corps (IRGC), and Ministry of Intelligence and Security (MOIS) under the terrorism exception to the Foreign Sovereign Immunities Act, seeking damages for alleged acts of terrorism. Plaintiffs moved for court approval to serve the IRGC and MOIS by email under the statute’s rules for agencies or instrumentalities of a foreign state. The court denied the motion, holding that those entities must instead be served under the stricter procedures that apply to the foreign state itself. It relied on D.C. Circuit precedent that classifies an entity as part of the foreign state when its core functions are governmental rather than commercial, a standard the plaintiffs did not dispute and had even acknowledged in their complaint. The court concluded that neither U.S. government terrorist designations nor the practical difficulties of serving Iran justified reclassifying the entities or authorizing service methods outside those Congress specified for foreign states.
The case involved a pro se plaintiff, John Michael Cohan, suing U.S. Trustee Program attorney Scott Bomkamp for alleged Fifth Amendment violations under Bivens, stemming from a Florida bankruptcy proceeding for Cohan’s company. Cohan claimed Bomkamp allowed his former romantic partner to join a 341 meeting in violation of a restraining order and edited the recording to conceal the misconduct, seeking millions in damages. The U.S. District Court for the District of Columbia granted Bomkamp’s motion to dismiss the amended complaint, denied Cohan’s related motions for an order to show cause and to amend further, and partially granted a request for judicial notice. The court reasoned that the claims presented a new Bivens context outside the three narrow Supreme Court precedents, and special factors—including Congress’s provision of alternative remedies through bankruptcy court motions and appeals to the Middle District of Florida—counseled against extending a damages action that would undermine the existing statutory scheme.
The case involved former Metropolitan Police Department Sergeant Enis Jevric’s motion under 28 U.S.C. § 2255 to vacate his convictions and sentence after he pled guilty to a federal civil rights violation (18 U.S.C. § 242) and D.C. involuntary manslaughter for fatally shooting An’Twan Gilmore during a 2021 traffic stop. Jevric argued that the government violated Brady v. Maryland by failing to disclose a 2009 on-duty encounter in which he had peacefully resolved a situation involving Gilmore, claiming this evidence would have undermined the willfulness element of the charges or served as mitigation at sentencing. The court denied the motion. It held that Brady is primarily a trial right that Jevric waived by pleading guilty, and even if construed as a challenge to the knowing and voluntary nature of his plea or to sentencing, the 2009 incident was not material because Jevric had no knowledge of Gilmore’s identity during the shooting, the evidence would not have affected his state of mind or been admissible at trial, and it would not have changed his decision to plead guilty or the sentence imposed.
In Fisher v. Clark Construction Group, LLC, pro se plaintiff Leon Fisher, Jr. sued multiple construction companies and individuals, alleging he was assaulted on a jobsite in January 2024, along with related claims of discrimination, retaliation, negligence, conspiracy, and emotional distress, after filing an EEOC charge and receiving right-to-sue letters. The U.S. District Court for the District of Columbia granted the defendants’ motions to dismiss and dismissed the complaint without prejudice under Federal Rule of Civil Procedure 8, while also dismissing claims against certain unserved defendants under Rule 4(m) for failure to prosecute. The court reasoned that the complaint, even as amended, failed to provide a short and plain statement of the claims or facts showing entitlement to relief, leaving defendants without fair notice of the alleged conduct, the legal bases for liability against each party, or the grounds for federal jurisdiction and venue. Although pro se pleadings are construed liberally, the court noted that they must still satisfy Rule 8’s notice requirements, and additional details in the plaintiff’s opposition briefs could not cure the defects in the operative complaint.
The case involved Accountability Now USA, an unincorporated association holding an NPS permit for a continuous demonstration on National Mall land urging President Trump’s impeachment. NPS officials, citing federal obscenity rules and 18 U.S.C. § 871 (threats against the President), directed removal of signs stating “TRUMP RAPED LITTLE GIRLS” and “KIDS, IF YOUR PARENTS ARE MAGA, THEY LOVE CHILD RAPISTS,” then later ordered takedown of a flag reading “8647,” warning that continued display would violate the permit. Plaintiff sought a temporary restraining order to bar enforcement actions against the flag. The district court granted the TRO. It reasoned that the site is a traditional public forum where content-based restrictions on political speech are presumptively unconstitutional, that “86” is common slang for removal or ejection rather than violence, and that the government had not shown the flag conveyed a true threat under an objective standard when viewed in context as a call for the President’s ouster from office.
The case involved two animal welfare groups challenging the National Park Service’s 2023 Free-Ranging Cat Management Plan, which replaced a long-running Trap-Neuter-Return program and authorized the removal of roughly 200 free-ranging cats from the Paseo del Morro trail within Puerto Rico’s San Juan National Historic Site. After no animal-welfare organizations submitted statements of interest, the NPS contracted with the Department of Agriculture’s Animal and Plant Health Inspection Service to carry out the removals, with cats deemed adoptable to be relocated and others euthanized. The plaintiffs contended that the NPS lacked authority over the trail without consulting Puerto Rican authorities, violated NEPA by preparing only an inadequate Environmental Assessment and Finding of No Significant Impact rather than a full Environmental Impact Statement, and breached the APA by failing to justify its policy reversal or address reliance interests and public comments. The court rejected these claims, holding that the trail lies within the park unit’s boundaries and that the NPS possesses broad statutory authority to manage it. The court further concluded that the agency’s NEPA documentation was sufficient and that its explanation for abandoning the prior TNR approach complied with the APA, and therefore granted summary judgment to the government.