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Oliver v. United States of America

2026-08-26

Summary

Holding. The court dismissed the amended complaint without prejudice because it failed to comply with Federal Rule of Civil Procedure 8(a), which requires a clear and plain statement of grounds for jurisdiction and a discernible claim for relief. The scattered, incoherent allegations did not provide fair notice to defendants or establish the court's subject matter jurisdiction.

A pro se plaintiff filed an amended complaint against approximately 35 defendants—including the United States, various states, foreign countries, federal agencies, hospitals, and individuals—seeking damages and equitable relief. The complaint contained disjointed allegations touching on diverse topics such as imprisonments, investigations, state court proceedings, mental health matters, and harassment, presented without clear connections or coherent narrative structure. The court found the pleading fundamentally deficient under the Federal Rules of Civil Procedure.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Compliance with Federal Rule of Civil Procedure 8(a) pleading requirements
  • Whether pro se litigants must follow the Rules of Civil Procedure
  • Adequacy of notice to defendants from a disjointed complaint

Procedural posture

The plaintiff filed an application to proceed in forma pauperis and an amended complaint in this civil action, which the court reviewed on initial submission.

Authorities cited

Opinion

majority opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

EDDIE V. OLIVER, III, )

)

Plaintiff, )

)

v. ) Civil Action No. 1:26-cv-01809 (UNA)

)

UNITED STATES OF AMERICA, et al., )

)

Defendants. )

MEMORANDUM OPINION

This matter is before the Court on its initial review of Plaintiff’s pro se Amended

Complaint (“Am. Compl.”), ECF No. 3, and Application for Leave to Proceed in forma pauperis

(“IFP”). The Court grants Plaintiff’s IFP Application, and for the reasons discussed below, it

dismisses the Amended Complaint, and this matter, without prejudice.

Plaintiff, a resident of Ohio, sues approximately 35 defendants, including the United States,

U.S. states, foreign countries, federal agencies, hospitals, and other entities and individuals. See

Am. Compl. at 1–2. It also appears that Plaintiff may attempt to bring this action on behalf of

other plaintiffs; indeed, it is unclear who is actually even bringing this case, see id. at 1, 5–6. In

any event, Plaintiff may not do so, because in federal court a plaintiff “may [only] plead and

conduct their own cases personally or by counsel.” 28 U.S.C. § 1654; Georgiades v. Martin–

Trigona, 729 F.2d 831, 834 (D.C. Cir. 1984) (individual “not a member of the bar of any court . .

. may appear pro se but is not qualified to appear in [federal] court as counsel for others”) (citation

and footnote omitted).

The allegations themselves are difficult to follow and involve a hodgepodge of anecdotes,

ranging in topics, including, inter alia, imprisonments, a “baby bible investigation,” local courts

in Ohio, “high crimes,” fraternity hazing, mental health diagnoses, substance abuse, harassment, marriage counseling, theft, and U.S. Supreme Court justices. See id. at 4–5. Plaintiff asks the

Court for damages and assorted equitable relief. See id.

Pro se litigants must comply with the Rules of Civil Procedure, see Jarrell v. Tisch, 656 F.

Supp. 237, 239–40 (D.D.C. 1987), and here, the Amended Complaint fails to comply with Rule

8(a) of the Federal Rules of Civil Procedure, which requires a pleading to contain “(1) a short and

plain statement of the grounds for the court’s jurisdiction [and] (2) a short and plain statement of

the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a); see Ashcroft v. Iqbal,

556 U.S. 662, 678–79 (2009); Ciralsky v. CIA, 355 F.3d 661, 668–71 (D.C. Cir. 2004). The Rule 8

standard ensures that defendants receive fair notice of the claim being asserted so that they can

prepare a responsive answer and an adequate defense and determine whether the doctrine of

res judicata applies. Brown v. Califano, 75 F.R.D. 497, 498 (D.D.C. 1977).

Plaintiff’s allegations are neither clear nor direct, see Fed. R. Civ. P. 8(d)(1), and the

paragraphs are not limited to a single set of circumstances, see Fed. R. Civ. P. 10(b). When, as

here, a pleading “contains an untidy assortment of claims that are neither plainly nor concisely

stated, nor meaningfully distinguished from bold conclusions, sharp harangues and personal

comments [,]” it does not fulfill the requirements of Rule 8. Jiggetts v. Dist. of Columbia, 319

F.R.D. 408, 413 (D.D.C. 2017), aff’d sub nom. Cooper v. Dist. of Columbia, No. 17-7021, 2017

WL 5664737 (D.C. Cir. Nov. 1, 2017). Put differently, “[a] confused and rambling narrative of

charges and conclusions . . . does not comply with the requirements of Rule 8.” Cheeks v. Fort

Myer Constr. Corp., 71 F. Supp. 3d 163, 169 (D.D.C. 2014) (citation and internal quotation marks

omitted). Plaintiff’s Amended Complaint falls squarely into this category, failing to provide the

Court or the Defendant with adequate notice of a claim, and falling short of establishing the Court’s

subject matter jurisdiction. See Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007) (“we do not require heightened fact pleading of specifics, but only enough facts to state a claim to relief that is

plausible on its face”); see also Iqbal, 556 U.S. at 679 (2009) (“Determining whether a complaint

states a plausible claim for relief will . . . be a context-specific task that requires the reviewing

court to draw on its judicial experience and common sense.”).

Accordingly, this matter is dismissed without prejudice. A separate Order accompanies

this Memorandum Opinion.

__________/s/_____________

Date: August 26, 2026 AMIT P. MEHTA

United States District Judge