Carl John Nichols

Derrick Allen Sr. filed a pro se complaint in the U.S. District Court for the District of Columbia against the State of North Carolina, its governor, and two state agencies, alleging that they indefinitely suspended his North Carolina driver’s license in retaliation for a prior lawsuit he filed against the DMV and seeking reinstatement plus damages of $372,000 or $512 billion. The court first noted that Allen failed to provide his address as required by local rules. It then dismissed the case without prejudice for lack of subject-matter jurisdiction, holding that the complaint raised no federal question because challenges to state driver’s-license decisions are governed by state law and Allen’s passing references to race and the Eighth and Fourteenth Amendments were too conclusory to support federal claims. The court further found no diversity jurisdiction, as Allen did not adequately plead his citizenship and failed to allege facts showing that his claimed damages met the $75,000 threshold.

civil rightsprocedurefederal power

The case involved a Guatemalan national in removal proceedings who applied for cancellation of removal, arguing that his deportation would cause exceptional and extremely unusual hardship to his disabled son, who qualified as a "child" under 21. An immigration judge indicated in 2024 that the application would likely be granted once annual statutory caps allowed, but the plaintiff sued in district court in 2026 for a preliminary injunction to fix the son's age as of the merits hearing date, fearing the son would soon turn 21 and lose qualifying-relative status. The court denied the motion, holding that it lacked jurisdiction under the Immigration and Nationality Act's zipper clause, 8 U.S.C. § 1252(b)(9), because the claim arose from ongoing removal proceedings and must instead be raised through a petition for review of a final order in the appropriate court of appeals. The court further noted that the plaintiff had not shown certain and imminent irreparable harm or that the balance of equities and public interest favored intervening in the administrative process before a final decision.

immigrationprocedure

In Atzili v. Islamic Republic of Iran, victims of the October 7, 2023 attacks sued Binance-related entities (BAM Management US Holdings, BAM Trading Services, and Binance Holdings Limited), alleging that the defendants’ inadequate sanctions, anti-money laundering, and know-your-customer controls on their cryptocurrency platforms allowed Hamas- and Iran-linked users to conduct transactions that supported the attacks, giving rise to claims under federal antiterrorism statutes and state tort law. The U.S. District Court for the District of Columbia granted the defendants’ motions to dismiss. The court held that aiding-and-abetting liability was not plausibly alleged because general knowledge that assistance reached a terrorist organization is insufficient under D.C. Circuit precedent in Atchley v. AstraZeneca UK Ltd. It further ruled that the claimed compliance defects did not constitute “activities” involving violent acts or acts dangerous to human life under 18 U.S.C. § 2331(1), so primary liability claims failed. With no federal claims remaining, the court declined supplemental jurisdiction over the state-law claims.

criminal lawbusiness & regulatorytorts & liability

In these consolidated cases, Democratic campaign committees and civil rights organizations challenged Executive Order 14,399, which directed federal agencies to strengthen citizenship verification for federal elections by requiring the Postal Service to propose mail-in ballot design rules and by compiling state lists of eligible citizen voters from federal records. The district court denied the plaintiffs’ motions for a preliminary injunction. It held that claims targeting the Postal Service rulemaking were unripe because no notice of proposed rulemaking had been issued and no final rule existed. For the citizenship-list provision, the court found that plaintiffs had not shown a likelihood of Article III standing or imminent irreparable harm, as the required infrastructure had not been built, no lists had been created or sent to states, and the Order imposed no obligations on states or the plaintiffs themselves. The court noted that the plaintiffs could renew their requests if concrete agency actions later materialized.

electionscivil rightsfederal powerprocedure

The case concerned Lorient Roxboro, LLC, an EB-5 new commercial enterprise, and its investor Vishnu Menon, who challenged USCIS denials of Lorient’s I-956F project application (due to a missed biometrics appointment and other deficiencies), Menon’s I-526E petition, and his I-485 adjustment-of-status application, seeking a stay of the I-485 denial to prevent accrual of unlawful presence. The district court denied Menon’s motion for a temporary restraining order or preliminary injunction staying the effective date of the I-485 denial. The court held that 8 U.S.C. § 1252(a)(2)(B)(i) and Patel v. Garland strip jurisdiction to review discretionary I-485 denials outside of removal proceedings in a court of appeals, that Menon’s due-process claim was not properly presented in that forum, and that success on the underlying I-956F challenge would not render the I-485 denial reviewable; it further found that equitable factors did not favor relief because any harm was not irreparable and immigration matters warrant deference to the Executive.

immigrationprocedure

James Adeyemi sued the Social Security Administration in federal district court, seeking a preliminary injunction and apparently challenging some agency action or decision. The magistrate judge issued a report recommending that the defendant’s motion to dismiss or for summary judgment be granted and that the plaintiff’s injunction request be denied. Neither party objected to the report within the required timeframe. The district judge therefore adopted the report in full as the court’s own findings and conclusions, granted summary judgment to the agency, denied the injunction, and closed the case as a final order.

federal powerprocedure

The case involved unaccompanied minors previously released by the Office of Refugee Resettlement (ORR) to approved sponsors but later re-referred to ORR custody, who challenged ORR’s requirement that their sponsors restart the full vetting process. Plaintiffs argued that this policy violated their constitutional due process rights and the Administrative Procedure Act by imposing unnecessary detention without individualized justification. The district court denied their motion for a preliminary injunction. It concluded that plaintiffs had not shown a likelihood of success on the merits, because ORR applies the same statutory sponsor-vetting requirements to all children in its custody—whether first-time or re-referred—and that the balance of equities and public interest weighed against immediate relief, particularly given the need for judicial deference in immigration matters and the availability of individual habeas remedies.

immigrationcivil rightsprocedurefederal power

In Smith v. Trump, a pro se plaintiff sued President Donald J. Trump in the U.S. District Court for the District of Columbia, alleging that Trump was unlawfully holding office because he had engaged in an insurrection in violation of Section Three of the Fourteenth Amendment, and seeking a writ of quo warranto to remove him. The court dismissed the case without prejudice, holding that it lacked subject-matter jurisdiction because the plaintiff lacked Article III standing. The opinion explained that the complaint alleged only a generalized grievance shared by all citizens regarding the lawfulness of the presidency, without identifying any concrete, particularized injury to the plaintiff personally that could be redressed by the court. Such claims, the court noted, fall outside the “cases” or “controversies” that federal courts may adjudicate under the Constitution.

electionsfederal powercivil rightsprocedure

The case involved an immigration law firm and a nonprofit organization that represent non-detained aliens in Minnesota, who sued the Executive Office for Immigration Review alleging that the agency had implemented an unwritten “Somali Fast-Track Policy” to rapidly advance hearing dates only for Somali asylum seekers, in violation of the Administrative Procedure Act; they sought a preliminary stay to revert the schedules. The government denied the existence of any such policy and argued that the plaintiffs lacked standing and could not obtain the requested relief. The court denied preliminary relief, reasoning that while the record indicated some coordinated effort affecting Somali cases, the primary harms fell on the non-party aliens themselves (who have separate avenues to challenge removal decisions), the organizations’ asserted operational and resource harms were not clearly irreparable or redressable by the court, and the plaintiffs had not met their burden to justify the extraordinary remedy of a stay.

immigrationprocedurefederal power

Christopher Easterling prevailed in an administrative proceeding under the Individuals with Disabilities Education Act, obtaining an order that the District of Columbia Public Schools had denied him a free appropriate public education and awarding him compensatory services such as tutoring and therapy. After the District initially imposed a deadline for using those services, Easterling filed a related federal lawsuit under 42 U.S.C. § 1983, which he later dismissed once the District clarified that using some services would not bar extensions for unused ones. He then sought $364,098.70 in attorneys’ fees and costs for both the administrative case and the federal action. The court held that Easterling qualified as a prevailing party under the IDEA fee-shifting provision because he obtained enforceable relief that altered the parties’ legal relationship, but it granted fees only in part after finding that some requested hourly rates and expert costs were not adequately justified as reasonable under prevailing community standards. The court also authorized post-judgment interest beginning 30 days after entry of the final fee order and directed Easterling to submit a revised petition.

civil rightsprocedure

Plaintiffs, three frequent Empower rideshare users, sued the company in federal court on behalf of a proposed class, alleging that it violated D.C. laws by failing to maintain required $1 million liability insurance, perform background checks on drivers, and disclose those requirements, allowing it to offer lower prices than competitors. The court granted Empower’s motion to dismiss, holding that the plaintiffs lacked Article III standing. It reasoned that the complaint alleged no concrete, particularized injury—no accidents occurred, no insurance gaps caused uncovered losses, and no plaintiff suffered harm from an inadequately vetted driver—leaving only a bare claim of regulatory noncompliance and a hypothetical risk that did not confer standing under Supreme Court precedent such as TransUnion v. Ramirez.

business & regulatoryprocedure

Green Climate, an environmental nonprofit focused on forest conservation, sued the Secretary of Agriculture to challenge a 2025 memorandum that designated tens of millions of acres of National Forest System land as “emergency situations,” authorizing expedited timber harvesting and related actions under Executive Order 14225. The government moved to dismiss, primarily arguing that the plaintiff lacked Article III standing. The district court granted the motion and dismissed the case for lack of jurisdiction. It held that the complaint failed to allege facts showing that Green Climate or any specifically identified member had suffered a concrete and particularized injury-in-fact from the memorandum, relying instead on generalized assertions of harm to forests and the environment that Supreme Court precedent deems insufficient. The court further noted that promises to supply member affidavits at a later stage could not cure the pleading deficiencies.

environmentprocedurefederal power

In Lytton Rancheria of California v. United States Department of the Interior, three Southern Pomo Indian tribes sued the Department of the Interior and related agencies, claiming the agencies had improperly rushed to take land into trust and approve a casino project proposed by the Koi Nation. While the government moved to transfer the case to the Northern District of California—where related challenges were already pending—a district court there granted partial summary judgment against the government and vacated the Interior action. The plaintiffs then moved to stay this case pending appeals in the related matters, which the U.S. District Court for the District of Columbia granted. The court concluded that judicial economy favored a stay because the Ninth Circuit’s rulings would likely affect transfer, the merits, and whether the plaintiffs would proceed at all, and the government had not shown any meaningful hardship from the temporary pause. The parties must file periodic status reports and propose next steps within 30 days of the Ninth Circuit’s mandate.

federal powerpropertybusiness & regulatoryprocedure

In Ebrahimi v. Trump, a pro se plaintiff sued President Trump, several federal officials, and more than 2,000 other defendants, claiming he had been subjected to decades of government-sanctioned sex trafficking, electronic surveillance, forced labor, wrongful prosecution, and other harms as part of a vast conspiracy. The government moved to dismiss the complaint. The U.S. District Court for the District of Columbia granted the motion and dismissed the case without prejudice, holding that it lacked subject-matter jurisdiction because the allegations were “patently insubstantial” and consisted of the sort of “bizarre conspiracy theories” that federal courts have no power to entertain. The court relied on precedents establishing that claims so attenuated and fictitious as to be devoid of merit must be dismissed under Rule 12(b)(1), and it therefore also denied the plaintiff’s requests for injunctive relief.

criminal lawcivil rightsfederal powerprocedure

The case involves a FOIA request by the Informed Consent Action Network seeking FDA records on polio vaccine clinical trial protocols. The government moved to stay the litigation until December 2026, citing the agency's massive ongoing obligations to produce millions of pages of COVID-19 vaccine documents in separate cases at rates of up to 230,000 pages per month. The court granted a partial stay under the Open America doctrine, finding that the unprecedented volume of compelled productions created "exceptional circumstances" and that the FDA demonstrated due diligence through its multi-queue processing system and staffing adjustments. It limited the stay to October 1, 2026—when the other productions are scheduled to end—rather than the longer period requested, and ordered a joint status report the following month.

healthcareprocedurebusiness & regulatory

Victoria White sued two Metropolitan Police Department officers under 42 U.S.C. § 1983, claiming they violated her Fourth Amendment rights by using excessive force against her during the January 6, 2021, Capitol riot—specifically, by striking her dozens of times with batons and punching her while she was in the Lower West Terrace Tunnel. The officers moved for judgment on the pleadings on qualified immunity grounds. The U.S. District Court for the District of Columbia granted the motion and dismissed the claims. It held that White failed to identify any precedent clearly establishing that the officers’ conduct—using force against members of a crowd pressing into the Capitol during an active riot in a confined tunnel setting—violated the Fourth Amendment as of January 6, 2021. The court also dismissed the related supervisory liability claim against one officer for the same reason.

civil rightsprocedure

In Park v. Brahmbhatt, plaintiff Shinok Park filed a pro se complaint in federal district court against Milan Brahmbhatt, seeking to quash a writ of fieri facias issued by the D.C. Superior Court to enforce a $150,000 attorney’s fee judgment and to stop the auction of her apartment, while alleging due process violations and raising complaints about prior local court proceedings. The United States District Court for the District of Columbia dismissed the complaint for lack of subject-matter jurisdiction and denied the plaintiff’s other pending motions as moot. The court reasoned that the Rooker-Feldman doctrine bars federal district courts from reviewing or interfering with decisions of D.C. courts or issues inextricably intertwined with them, and Park’s claims were directly tied to the Superior Court proceedings rather than presenting independent federal claims.

civil rightsfederal powerpropertyprocedure

Alex Lemu sued his former employer, Factory Mutual Insurance Company, claiming constructive discharge in violation of public policy. He alleged that after notifying managers about overdue boiler inspections—including one at Sibley Memorial Hospital—and reporting a subsequent boiler incident to D.C. authorities, he received a final written warning for performance issues and resigned. The U.S. District Court for the District of Columbia granted Factory Mutual’s motion to dismiss. The court concluded that Lemu’s filings failed to allege facts showing the company forced him to violate the law, knew of his report, or terminated him for that reason, and that he had not identified any clear public policy mandate under D.C. law that the alleged discharge violated.

labor & employment

Gerald Da’Vage, an African American project superintendent, sued WCS Construction, LLC, and two supervisors under Title VII, 42 U.S.C. § 1981, and the D.C. Human Rights Act, alleging that his April 2021 termination was due to race discrimination. The district court granted WCS’s motion for summary judgment after discovery. The court found that WCS had produced extensive, contemporaneous documentation of performance deficiencies—including failures to conduct site walks, maintain cleanliness and organization, complete reports and inspections, manage subcontractors, and obtain authorization for work—that began shortly after Da’Vage’s July 2019 hire and continued across two projects. Da’Vage did not present evidence creating a genuine dispute that these stated reasons were pretextual, and his aiding-and-abetting claims against the individual defendants necessarily failed once the primary claims against the company were dismissed.

civil rightslabor & employment

In Adaeze Nwosu v. Federal Bureau of Investigation, a pro se plaintiff sued the FBI, Department of Homeland Security, Supreme Court employees Scott Harris and Robert Meek, Yale University, Senator Chris Van Hollen, the United States, and The New York Times, asserting claims of fraud and gross negligence based on allegations that the defendants mishandled her prior court filings, engaged in discrimination and collusion, failed to prevent or report racism, and made improper admissions or editorial decisions. The Times and the government moved to dismiss under Federal Rules 12(b)(1) and 12(b)(6), arguing lack of jurisdiction, failure to state a claim, and other deficiencies, while Nwosu filed an unsupported motion for summary judgment but never responded to the dismissal motions or complied with a court order to demonstrate proper service on the remaining defendants. The U.S. District Court for the District of Columbia granted the motions to dismiss, denied the summary judgment motion, and dismissed the entire case without prejudice. The court reasoned that Nwosu’s failure to respond allowed it to treat the motions as conceded under Local Civil Rule 7(b), that the identified pleading deficiencies appeared valid, and that her overall lack of diligence—including ignoring explicit warnings and orders—warranted dismissal for failure to prosecute under Rule 41(b).

procedurecivil rightstorts & liability