Christopher Reid Cooper

Kevin Anderson, a former partner at accounting firm BDO USA, sued under ERISA to recover retirement benefits he claimed had accrued during the 54 months he worked as a salaried employee after retiring from the partnership in June 2019 but before fully separating from the firm in December 2023. He argued that the partnership agreement deferred those payments until his separation from service under IRC Section 409A, requiring BDO to pay them as a lump sum starting in January 2024. The court denied Anderson’s motion for judgment and granted BDO’s cross-motion, holding that the governing agreements provided only for prospective monthly payments of the annual retirement benefit beginning after a partner’s separation from service as an employee. The Retirement Agreement, whose terms controlled in any conflict, stated that Anderson would “start receiving retirement benefits commencing” the month after his separation, with no language providing for accrual or lump-sum catch-up payments during continued employment. Section 7.9(a) of the partnership agreement similarly conditioned the start of payments on separation from service under Section 409A but did not establish any right to benefits for periods before that date.

labor & employmentbusiness & regulatorytaxes

In Verduzco v. United States Department of Justice, plaintiff Susana Verduzco sued the DOJ, the Office of the Attorney General, the U.S. Attorney’s Office for the District of Arizona, and a government attorney, alleging that federal officials had improperly certified a VA doctor as a federal employee acting within the scope of her duties, removed Verduzco’s prior medical malpractice suit to federal court, and otherwise engaged in deceitful litigation conduct following an alleged non-consensual procedure in 2017. She asserted a Bivens claim for constitutional violations, an intentional infliction of emotional distress claim, and a “fraud on the court” claim. The U.S. District Court for the District of Columbia granted the defendants’ motion to dismiss all claims with prejudice under Rule 12(b)(1). The court held that sovereign immunity barred the Bivens claims because the defendants were federal agencies or an official sued only in her official capacity, that the IIED claim was not properly brought under the FTCA and had not been administratively exhausted, and that the fraud claim was similarly barred by sovereign immunity or the FTCA’s intentional-tort exception.

civil rightsfederal powerproceduretorts & liability

In Williams v. Department of Housing and Urban Development, plaintiff Juan T. Williams, a Georgia resident appearing pro se, filed suit complaining that it was “shameful” for unhoused individuals to camp outside the Martin Luther King Library in Washington, D.C., and seeking “reasonable accommodations” for unhoused people nationwide. The U.S. District Court for the District of Columbia granted Williams’s request to proceed without prepaying fees but dismissed the complaint without prejudice. The court held that it lacked subject-matter jurisdiction because Williams failed to allege any personal injury traceable to the defendants’ conduct, as required for Article III standing. It further ruled that, as a non-attorney, Williams could not represent the interests of other unhoused individuals in federal court.

civil rightsfederal powerprocedure

In McKeeman v. Bush, plaintiff Rita Faye McKeeman, proceeding pro se, filed a civil complaint against Steven Bush and other defendants in the U.S. District Court for the District of Columbia, along with an application to proceed in forma pauperis. The court granted the application but dismissed the complaint without prejudice. The dismissal occurred because the complaint contained no factual allegations supporting a legal claim, no statement establishing the court’s subject matter jurisdiction, and no demand for relief, failing to satisfy the short and plain statement requirements of Federal Rule of Civil Procedure 8(a) even under the less stringent standard applied to pro se filings.

procedure

In McKeeman v. Black Charley, a pro se plaintiff sued multiple defendants in the U.S. District Court for the District of Columbia and asked to proceed without paying filing fees. The court granted the fee waiver but dismissed the complaint without prejudice. It found that the filing contained no factual allegations supporting any legal claim, no statement establishing the court’s subject-matter jurisdiction, and no request for relief, all of which are required by Rule 8 of the Federal Rules of Civil Procedure. Although pro se complaints receive a more lenient reading, they must still satisfy these basic pleading standards so defendants receive fair notice of the claims.

procedure

In McKeeman v. Jeffer Family Member, pro se plaintiff Rita Faye McKeeman filed a civil complaint in the U.S. District Court for the District of Columbia against the named defendants. The court granted her application to proceed in forma pauperis but dismissed the complaint without prejudice. The court explained that even under the more lenient standard applied to pro se filings, the complaint failed to meet Federal Rule of Civil Procedure 8(a) because it contained no factual allegations supporting a legal claim, no statement establishing subject-matter jurisdiction, and no demand for relief.

procedure

In McKeeman v. Chaney, a pro se plaintiff filed a complaint in the U.S. District Court for the District of Columbia against Richard Chaney family members and other defendants, along with an application to proceed in forma pauperis. The court granted the application but dismissed the complaint without prejudice. The dismissal rested on the complaint's failure to satisfy Federal Rule of Civil Procedure 8(a), as it contained no factual allegations supporting a legal claim, no statement establishing the court's subject matter jurisdiction, and no demand for relief. Although pro se pleadings receive a less stringent review than those drafted by counsel, the court noted that they must still meet the rule's basic requirements for providing fair notice to defendants.

procedure

In Pinzon v. United States Department of Justice, pro se plaintiff Abraham G. Pinzon sued the Department of Justice, the FBI, the Governor of California, and others, alleging vague wrongdoing related to his Social Security benefits, including claims of criminal activity, judicial misconduct, racketeering, and embezzlement. The U.S. District Court for the District of Columbia granted Pinzon’s application to proceed in forma pauperis but dismissed the complaint without prejudice and denied his motion for injunctive relief as moot. The court explained that, although pro se pleadings receive more lenient review, they must still satisfy Federal Rule of Civil Procedure 8(a), which requires a short and plain statement of the court’s jurisdiction, the claim showing entitlement to relief, and the relief sought. The complaint failed this standard because its rambling and unclear allegations did not articulate any viable legal claim or provide fair notice to the defendants.

procedurecriminal lawfederal power

In McKeeman v. Randy, a pro se plaintiff filed a complaint in the U.S. District Court for the District of Columbia along with an application to proceed in forma pauperis. The court granted the application but dismissed the complaint without prejudice. The court explained that even under the less stringent standard applied to pro se filings, the complaint failed to satisfy Federal Rule of Civil Procedure 8(a), as it contained no factual allegations supporting a legal claim, no statement establishing the court's subject-matter jurisdiction, and no demand for relief. The dismissal was based solely on these pleading deficiencies.

procedure

In McKeeman v. Chaney, a pro se plaintiff filed a complaint in the U.S. District Court for the District of Columbia against Richard Chaney and other defendants, along with an application to proceed in forma pauperis. The court granted the application but dismissed the complaint without prejudice. The dismissal was based on the complaint's failure to include any factual allegations supporting a legal claim, a statement establishing the court's subject matter jurisdiction, or a demand for relief, as required by Federal Rule of Civil Procedure 8(a). Although pro se complaints are reviewed under less stringent standards, they must still meet basic pleading requirements to provide fair notice to defendants.

procedure

In Alexander v. Amtrak, a pro se plaintiff sued Amtrak and Amtrak Police in the U.S. District Court for the District of Columbia, alleging fraud, breach of an agreement, violations of terms and conditions, false statements that led to his arrest, and resulting near-fatal medical complications, while seeking $50 million in damages. The court granted the plaintiff's application to proceed in forma pauperis but dismissed the complaint without prejudice. The dismissal rested on Federal Rule of Civil Procedure 8(a), which requires a short and plain statement of the court's jurisdiction and the claim showing entitlement to relief; the complaint provided only vague, conclusory allegations without any supporting details, legal citations, or context about the timing, location, or specific conduct at issue, leaving defendants without fair notice of the claims.

proceduretorts & liability

Anthony Brian Mallgren filed a pro se complaint against the United States and other defendants in the U.S. District Court for the District of Columbia, along with an application to proceed in forma pauperis without paying filing fees. The court granted the fee waiver but dismissed the complaint. It found that the complaint’s few factual allegations were unintelligible and, to the extent they could be understood, were irrational and incredible. Because the claims lacked any arguable basis in law or fact and were deemed frivolous under precedents such as Ashcroft v. Iqbal and Neitzke v. Williams, the court held it lacked subject-matter jurisdiction and was required to dismiss the case.

procedure

In Banks v. Farello, a pro se plaintiff sued approximately 30 state and federal agencies and officials across Maryland, Virginia, and the District of Columbia, seeking equitable relief and at least $500 million in damages for alleged government conspiracies to retaliate against him for filing prior lawsuits, including claims brought on behalf of his minor child. The U.S. District Court for the District of Columbia granted the plaintiff's application to proceed in forma pauperis but dismissed the complaint without prejudice. The court held that the complaint violated Federal Rule of Civil Procedure 8(a) by failing to provide a short and plain statement of the grounds for jurisdiction or the claims for relief. It found the allegations vague, overly broad, and rambling rather than clear, direct, and limited to single sets of circumstances, leaving defendants without fair notice and failing to establish plausible claims or subject-matter jurisdiction.

civil rightsprocedurefederal power

In Stephanie Mykonos v. DC Government, a pro se plaintiff sued the District of Columbia, alleging that it violated the D.C. Human Rights Act by denying her Medicaid benefits on the basis of pregnancy, age, and homeless status. The U.S. District Court for the District of Columbia granted the plaintiff's application to proceed in forma pauperis but dismissed the complaint without prejudice. The court explained that, although pro se pleadings receive some leniency, they must still satisfy Federal Rule of Civil Procedure 8(a) by providing a short and plain statement of the claim and the court's jurisdiction. Here, the complaint contained no factual allegations showing that the plaintiff was actually pregnant or over 40, nor any clear link between those characteristics and the denial of benefits, leaving the defendant without fair notice of the claims.

civil rightshealthcareprocedure

In McKeeman v. Famelmers, a pro se plaintiff filed a complaint in the U.S. District Court for the District of Columbia against the named defendant, along with an application to proceed in forma pauperis. The court granted the application but dismissed the complaint without prejudice. It held that the pleading failed to satisfy the minimal requirements of Federal Rule of Civil Procedure 8(a), as it contained no statement of the court’s jurisdiction, no factual allegations supporting a legal claim, and no demand for relief. Although pro se complaints are reviewed under a less stringent standard than those drafted by counsel, they must still provide defendants with fair notice of the claims asserted. The dismissal allows the plaintiff an opportunity to file an amended complaint that meets these standards.

procedure

In McKeeman v. Chaney, a pro se plaintiff filed a complaint in the U.S. District Court for the District of Columbia against Dick Chaney and other defendants, along with an application to proceed in forma pauperis. The court granted the application but dismissed the complaint without prejudice. The decision rested on the complaint's failure to satisfy Federal Rule of Civil Procedure 8(a), as it contained no factual allegations supporting a legal claim, no statement establishing the court's jurisdiction, and no demand for relief. Although pro se filings receive a less stringent standard, they must still provide defendants with fair notice of the claims. The court found the pleading fell well short of this minimal threshold.

procedure

The case involved a pro se plaintiff, Anthony Brian Mallgren, who sued United Healthcare and others in the U.S. District Court for the District of Columbia, seeking remedies such as the immediate disbandment of the U.S. healthcare system and the end of all medical licensing, based on an encounter with staff at a health club to which the defendant had referred him. The court granted the plaintiff's request to proceed in forma pauperis but dismissed the complaint without prejudice. It held that the complaint failed to state a plausible claim under federal pleading standards and was frivolous because its factual allegations were unintelligible, irrational, or wholly incredible. As a result, the court lacked subject-matter jurisdiction over such a suit, which was deemed too attenuated and unsubstantial to merit consideration.

healthcareprocedure

In Hanan Shiheiber v. J.P. Morgan Chase Bank, N.A., a pro se plaintiff sued the bank and other defendants in federal court, seeking an award of $3.3 million and referencing prior correspondence and state court filings. The U.S. District Court for the District of Columbia granted the plaintiff’s application to proceed without paying fees but dismissed the complaint without prejudice. The court held that the pleading failed to satisfy Federal Rule of Civil Procedure 8, which requires a short, plain statement of the court’s jurisdiction, the legal claims, and the relief sought. The opinion noted that the complaint contained no meaningful facts or clear allegations, making it impossible for defendants to understand or respond to any asserted claims. Although pro se filings receive some leeway, the court explained they must still meet basic pleading standards to provide fair notice.

procedure

In Mallgren v. United States, plaintiff Anthony Brian Mallgren, proceeding pro se, sued the United States alleging that the Patent and Trademark Office could not locate a patent application filed around 2007 and demanding that the government implement a public blockchain system to enhance integrity in the patenting process. The U.S. District Court for the District of Columbia granted the plaintiff's application to proceed in forma pauperis but dismissed the complaint without prejudice. The court found that the complaint violated Federal Rule of Civil Procedure 8(a) by failing to provide a short and plain statement of jurisdiction or any claim that would give fair notice to the defendant. It further held that the plaintiff had not established subject matter jurisdiction and that the court lacked authority to order the specific relief sought, such as compelling particular agency actions under the Administrative Procedure Act.

business & regulatorypropertyprocedurefederal power

In Mallgren v. United States, a pro se plaintiff residing in New York sued the federal government, alleging that it had lost his patent application, allowed fraud in the justice system and government programs like Medicare and Medicaid, manipulated diagnoses to discredit people, and violated his human rights, while also asking the court to repeal the Eleventh Amendment and strike down laws against medically assisted suicide. The U.S. District Court for the District of Columbia granted the plaintiff's request to proceed without paying fees but dismissed the complaint without prejudice. The court reasoned that the filing failed to meet the requirements of Federal Rule of Civil Procedure 8(a), which demands a short and plain statement of the grounds for jurisdiction and the claims for relief, because the allegations were unclear, rambling, and spread across unrelated topics without providing fair notice to the defendant or establishing subject-matter jurisdiction.

civil rightsfederal powerhealthcareprocedure