UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
LATOSHA A. WARD,
Plaintiff,
v. Civil Action No. 25 - 2370 (LLA)
BOOZ ALLEN HAMILTON,
Defendant.
MEMORANDUM OPINION AND ORDER
Dr. Latosha A. Ward, proceeding pro se, brings this action against Defendant Booz Allen
Hamilton (“Booz Allen”). ECF No. 1. She alleges various legal claims related to her former
employment with the company. Id. Pending before the court are Booz Allen’s motion to dismiss,
ECF No. 10; Dr. Ward’s motions to strike, ECF Nos. 18, 19, which Booz Allen opposes, ECF
No. 20; and Dr. Ward’s motion for leave to file a supplement to her complaint, ECF No. 23, which
Booz Allen opposes, ECF No. 24. For the reasons that follow, the court grants Booz Allen’s
motion to dismiss to the extent that the court dismisses Dr. Ward’s complaint without prejudice
for failure to comply with Federal Rule of Civil Procedure 8, but it grants Dr. Ward leave to file
an amended complaint within thirty days. The court otherwise denies Booz Allen’s motion without
prejudice to reraising any arguments as they concern the amended complaint, and it denies
Dr. Ward’s pending motions as moot.
Rule 8(a) requires that a complaint include: (1) “a short and plain statement of the grounds
for the court’s jurisdiction,” (2) “a short and plain statement of the claim showing that the pleader
is entitled to relief,” and (3) “a demand for the relief sought.” Fed. R. Civ. P. 8(a)(1)-(3). These rules ensure that defendants have “notice of what the . . . claim is and the grounds upon which it
rests.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (alteration in original) (quoting
Conley v. Gibson, 355 U.S. 41, 47 (1957)). Although filings by pro se litigants are held to less
stringent standards than those drafted by lawyers, all litigants must follow the Federal Rules.
Jarrell v. Tisch, 656 F. Supp. 237, 239 (D.D.C. 1987).
A court may dismiss a complaint that fails to adhere to the requirements of Rule 8 either
upon a motion or sua sponte. See Fed. R. Civ. P. 41(b); see also Ciralsky v. Cent. Intel. Agency,
355 F.3d 661, 669 (D.C. Cir. 2004) (noting that “Rule 41(b) authorizes the court to dismiss either
a claim or an action because of the plaintiff’s failure to comply with the Federal Rules”). “When
a trial court concludes that an initial complaint fails to satisfy Rule 8, an appropriate remedy is to
strike the complaint . . . and to provide the plaintiff with an opportunity to file an amended
complaint that complies with the Rules.” Jiggetts v. District of Columbia, 319 F.R.D. 408, 413-14
(D.D.C. 2017) (alteration in original) (quoting Achagzai v. Broad. Bd. of Governors, 109 F. Supp.
3d 67, 69 (D.D.C. 2015)), aff’d sub nom., Cooper v. District of Columbia, No. 17-7021, 2017 WL
5664737 (D.C. Cir. Nov. 1, 2017).
Dr. Ward’s complaint fails to meet Rule 8(a)’s minimal pleading standards. First, the
laundry list of legal authorities under which Dr. Ward seeks relief is untethered to her factual
allegations, rendering it impossible for the court to discern which facts are intended to support
which claims. Rather than stating distinct causes of action supported by her factual allegations,
Dr. Ward provides a Table of Authorities listing over twenty federal and District of Columbia
laws, federal regulations, and a Department of Defense policy. ECF No. 1, at 13-15. 1 To be sure,
1
When citing ECF No. 1, the court refers to the CM/ECF-generated numbers at the top of each page rather than any internal pagination.
2
the court can discern that Dr. Ward intends to bring some number of employment discrimination
claims based on some combination of protected characteristics. Id. at 80-83. But it is unclear
whether she also intends to assert independent claims based on the remaining cited authorities, as
many are only listed in passing in the complaint, and, as Booz Allen points out, many of these laws
are facially inapplicable to Dr. Ward’s case. See ECF No. 10-1, at 33-34 (explaining that several
of the statutes and regulations only apply to government actors); id. at 35-36 (explaining that
several of the listed authorities lack a private right of action).
For example, while Dr. Ward alleges “breaches” of the Family Education Rights and
Privacy Act, 20 U.S.C. § 1232g, ECF No. 1, at 14, 81, she does not allege that Booz Allen is an
“educational agency or institution” covered by that statute or otherwise explain how the statute
applies to her case, see 20 U.S.C. § 1232g(a)(1)(A). She also lists several criminal statutes and
claims that she is entitled to relief under 18 U.S.C. § 2327, which provides for mandatory
restitution to victims of crimes. ECF No. 1, at 13. But it is well established that criminal statutes
generally do not provide a basis for a plaintiff to bring a private civil action. See Lee v. U.S. Agency
for Int’l Dev., 859 F.3d 74, 77-78 (D.C. Cir. 2017) (per curiam) (“Although the express ‘provision
of a criminal penalty does not necessarily preclude implication of a private cause of action for
damages,’ such a provision in a ‘bare criminal statute,’ with no other statutory basis for inferring
that a civil cause of action exists, is insufficient to imply Congress intended to create a concomitant
civil remedy.” (quoting Cort v. Ash, 422 U.S. 66, 79-80 (1975))); see also Jackson v. Donovan,
856 F. Supp. 2d 147, 149 (D.D.C. 2012). The same is true of the Federal Rules of Civil Procedure
and the Local Rules of the U.S. District Court for the District of Columbia. See ECF No. 1, at 14.
It is possible that Dr. Ward is only referencing some of these authorities to support her employment
discrimination claims, particularly because she has listed them in a “Table of Authorities” that
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immediately precedes a list of “Scholarly Texts.” ECF No. 1, at 15-17. But the court cannot assess
the plausibility of Dr. Ward’s claims unless it can “readily discern what claims are being made in
relation to what conduct.” Jiggetts, 319 F.R.D. at 416; see id. at 417 (“The fact that there are
multiple legal theories smooshed into each of the counts merely muddles matters, and thereby
exacerbates the lack-of-clarity problem.”). And even if the court could discern which claims
Dr. Ward seeks to assert, her “myriad factual allegations are entirely divorced from the various
legal claims that [she] assert[s].” Id. at 416.
Many of Dr. Ward’s allegations sound in employment discrimination, primarily under
Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq., the Americans with
Disabilities Act (“ADA”), 42 U.S.C. § 12101 et seq., and the D.C. Human Rights Act
(“DCHRA”), D.C. Code § 2-1401.01 et seq. See ECF No. 1, at 3. But even as to her employment
discrimination claims, there are “no well-pled factual allegations that describe this . . . streak of
unlawful conduct with any degree of detail capable of providing ‘fair notice’ to Defendant[] as to
the basis of this action.” Dalbis v. Pub. Emps. of Sec. & Intel. Servs. of Fr. & Eur.,
No. 24-CV-1434, 2024 WL 3338802, at *1 (D.D.C. July 9, 2024). Instead, Dr. Ward makes
conclusory assertions that Booz Allen violated the law. See, e.g., ECF No. 1, at 9 (stating that
“marital status discrimination occurred from Booz Allen Hamilton on several occasions when an
employer denies an employee employment or promotions, harasses, pays less, or otherwise takes
negative employment action against an employee because of the employee’s status as recently
single or formerly married Veteran spouse who became divorced after her hire date”); id. at 10
(stating that Booz Allen violated the ADA because it “took both illegal and retaliatory actions
against [Dr.] Ward for interviewing with a new Career Manager after experiencing discrimination
from her current team” and then “create[ed] libel” as to “the reason for [her] termination[]”); id.
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at 10 (asserting that “Booz Allen Hamilton continues to “defy federal, state, and local due process
while spreading misinformation across local, national, and global systems and teams by
unethically involving these unbeknownst agencies and its representatives with blatant libel,
slander, extended discrimination, and retaliations”); id. at 11 (alleging generally that she
“continues to be the target of retaliation that has resulted in extreme PHI, PII, and HIPPA violations
and unjustified reviews and audits”). The Rule 8 pleading standard requires more than “an
unadorned, the-defendant-unlawfully-harmed me accusation” or a “‘formulaic recitation of the
elements of a cause of action.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly,
550 U.S. at 555). Thus, even as to the legal claims that arise out of Dr. Ward’s underlying Equal
Employment Opportunity Commission proceedings, Dr. Ward fails to allege specific facts tethered
to each claim that could enable the court to assess the plausibility of her complaint. See Jiggetts,
319 F.R.D. at 417 (explaining that the legal standards for different discrimination statutes are “not
interchangeable” and dismissing the complaint under Rule 8 where the plaintiff “did not take care
to analyze the facts that give rise to each count or the legal standards upon which they turn”).
What is more, Dr. Ward’s factual allegations are obscured by irrelevant or extraneous
material. See, e.g., ECF No. 1 at 15-17 (list of “Scholarly Texts” including “Maslow’s Hierarchy
of Needs,” resources for victims of domestic and sexual violence, and various government
websites); id. at 60 (a screenshot of a time sheet that Dr. Ward alleges was “[a]ltered” to be late
and non-compliant with company policy); id. at 61 (two Microsoft Outlook calendar entries for
canceled meetings); id. at 79 (pictures of a group of people, including Dr. Ward, at a company
event). Dr. Ward’s factual statement spans over fifty pages of her complaint, in large part because
the statement is peppered with over twenty “exhibits” that Dr. Ward describes as “[i]rrefutable
evidence” of her claims. See id. at 22-80. But, at the pleading stage, a plaintiff is not required to
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provide evidence of the truth of her allegations; rather, the complaint need only “contain sufficient
factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Iqbal, 556
U.S. at 678 (quoting Twombly, 550 U.S. at 570). “[B]ecause the [complaint] contains seemingly
irrelevant and unnecessary facts, the actual factual basis of [Dr. Ward’s] legal claims (whatever it
may be) is obscured, which makes the pleading hopelessly confusing.” Jiggetts, 319 F.R.D. at 415;
see Achagzai, 109 F. Supp. 3d at 71 (“Where a complaint is insufficiently focused, it places an
undue burden on the defendant to answer or move and it invites unnecessary delay and confusion
in the proceedings.”)
Dr. Ward’s other filings only exacerbate this confusion. In her oppositions, rather than
responding to the arguments in the motion to dismiss, Dr. Ward lists Booz Allen’s attorneys’
ethical responsibilities and disclosure obligations under Federal Rule of Civil Procedure 26. See
generally ECF Nos. 13, 15. These arguments are both non-responsive to Booz Allen’s motion to
dismiss and they lack merit: Federal Rule of Civil Procedure 26 is inapplicable at this juncture
because litigation has not yet proceeded past the pleading stage, and to the extent that Dr. Ward is
suggesting that the attorneys representing Booz Allen have engaged in ethical misconduct, that
contention is unsupported by the record. Nor does Dr. Ward’s proposed supplemental complaint
clarify the matter. In her proposed supplement, Dr. Ward states that she seeks to provide
“additional factual allegations and violations that occurred subsequent to the original filing.” ECF
No. 23, at 1. But she appears to instead bring entirely new legal claims including post-filing
retaliation (without specifying her cause of action or the alleged protective activity), “the illegal
suppression of a whistleblower’s claims under the ADA and ERISA,” “[s]poliation,” and
“[p]ost-[f]iling [m]isinformation.” Id. (internal quotation marks omitted).
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Courts have not hesitated to reject pleadings with similar defects under Rule 8(a). See,
e.g., Bell v. District of Columbia, No. 23-CV-2036, 2024 WL 2846770, at *5 (D.D.C. June 5,
2024) (dismissing a complaint that required a “mighty endeavor to understand how the additional
allegations connect to [the plaintiff’s] legal claims, or how the allegations included under each
count should fit in to the Complaint’s overall narrative”); Kelleher v. Regan, No. 23-CV-1346,
2023 WL 8600507, at *1 (D.D.C. Nov. 27, 2023) (dismissing a complaint that “offer[ed] a
‘rambling, disjointed, incoherent’ discussion” (quoting Jiggetts, 319 F.R.D. at 413)); Spence v.
U.S. Dep’t of Veterans Affs., No. 19-CV-1947, 2022 WL 3354726, at *12 (D.D.C. Aug. 12, 2022)
(dismissing a complaint and explaining that the allegations in one count “linger[ed] on the minutiae
of ‘myriad seemingly irrelevant descriptions’ of correspondence between [the plaintiff] and her
supervisors about particular work assignments, rather than providing a coherent chronological
retelling of the events underlying her termination” (citations omitted) (quoting Jiggetts, 319 F.R.D.
at 415)), aff’d, 109 F.4th 531 (D.C. Cir. 2024); Brown v. Wash. Metro. Area Transit Auth., 164 F.
Supp. 3d 33, 35 (D.D.C. 2016) (dismissing a complaint sua sponte, after motions briefing, for
being “unintelligible”).
Booz Allen argues that the court should dismiss Dr. Ward’s complaint with prejudice, ECF
No. 10-1, at 37-38, and deny her motion for leave to supplement, ECF No. 24. It also argues that
by failing to respond to its arguments in the motion to dismiss, Dr. Ward has conceded the motion
to dismiss. See ECF No. 14, at 1. The court recognizes that Booz Allen did its best to parse an
unintelligible complaint, but the motion to dismiss only underscores the court’s Rule 8 conclusion
because even Booz Allen does not know exactly what claims Dr. Ward seeks to bring. See, e.g.,
ECF No. 10-1, at 16-17 (explaining that, because many of Dr. Ward’s factual allegations are not
connected to a specific date, Booz Allen was unable to assess whether they were timely); id. at 29
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(arguing that “if [Dr. Ward] has alleged an [Equal Pay Act] claim, the Court should dismiss it”);
id. at 29-30 (same for Dr. Ward’s failure-to-accommodate claim).
Given Dr. Ward’s pro se status, the court will permit Dr. Ward another opportunity to file
a complaint that complies with Rule 8. See Ciralsky, 355 F.3d at 668-69. In her amended
complaint, Dr. Ward must “distill[] the facts [and legal theories] into a coherent recitation of
essential information,” rather than “load[] up [her] pleading with every conceivable detail that
relate[s] to any and all aspects of [her claims].” Jiggetts, 319 F.R.D. at 418. And she must clearly
identify each cause of action and state the facts that support the elements of each legal claim.
Dr. Ward is advised that if she files an amended complaint that repeats the missteps described
above, the court will dismiss the case with prejudice. See Brown, 164 F. Supp. 3d at 35 (warning
the plaintiff that if he “file[d] an amended complaint that merely recycle[d] the complaint [that had
been previously dismissed under Rule 8,] it may be dismissed with prejudice” (quoting Hamrick
v. United States, No. 10-CV-857, 2010 WL 3324721, at *1 (D.D.C. Aug. 24, 2010))).
For the foregoing reasons, it is hereby ORDERED that Booz Allen’s Motion to Dismiss,
ECF No. 10, is GRANTED to the extent that the court will dismiss Dr. Ward’s complaint without
prejudice but is otherwise DENIED. It is further ORDERED that Dr. Ward’s Complaint, ECF
No. 1, is DISMISSED without prejudice, but Dr. Ward is granted leave to file an amended
complaint that complies with Federal Rule of Civil Procedure 8 on or before September 23, 2026.
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Finally, it is further ORDERED that Dr. Ward’s motions to strike, ECF Nos. 18, 19, and motion
for leave to file a supplement to her complaint, ECF No. 23, are DENIED as moot.
SO ORDERED.
LOREN L. ALIKHAN
United States District Judge
Date: August 24, 2026
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