Rodriguez v. Harris

2026-08-28

Summary · law.co

Holding. The court granted the defendant's motion to dismiss the amended complaint under Federal Rule of Civil Procedure 8(a) for failure to state a claim with sufficient factual and legal specificity, and alternatively under Rule 12(b)(1) for lack of subject matter jurisdiction over frivolous claims.

Suzette Grace Rodriguez, representing herself, filed suit against Scott Sessions Harris, the Clerk of the Supreme Court, alleging a conspiracy between Harris and the U.S. Postal Service involving mail fraud that caused her homelessness. The case was initially dismissed for failing to comply with pleading standards. When Rodriguez filed an amended complaint, the court found it similarly deficient—the allegations remained vague and failed to connect specific facts to legal claims, leaving the defendant unable to understand or respond to the charges.

The court granted the defendant's motion to dismiss on two independent grounds. First, the amended complaint violated Federal Rule of Civil Procedure 8 by failing to provide fair notice of the claims and factual basis, despite the plaintiff having received explicit instructions on how to cure the defects. Second, the court determined it lacked subject matter jurisdiction because the allegations—describing a conspiracy between a federal judicial officer and a government agency to cause homelessness and manslaughter—were irrational and wholly incredible, rendering the complaint frivolous.

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

Key issues

Whether pro se complaint satisfied Rule 8 pleading standards
Whether court had subject matter jurisdiction over allegations deemed irrational and incredible
Standards for dismissing frivolous complaints lacking arguable basis in law or fact

Procedural posture

The plaintiff's original pro se complaint was dismissed for unintelligibility, and the defendant moved to dismiss the amended complaint for failure to cure defects and for lack of subject matter jurisdiction.

Authorities cited

Opinion · public domain

majority opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

SUZETTE GRACE RODRIGUEZ,

Plaintiff,

v. No. 26-cv-02319 (DLF)

SCOTT SESSIONS HARRIS,

Defendant.

MEMORANDUM OPINION

Suzette Grace Rodriguez filed this action pro se in the Superior Court of the District of

Columbia against Scott Sessions Harris, the Clerk of the Supreme Court of the United States.

Compl., Dkt. 1-1. Harris removed the case to this Court. See Dkt. 1. On July 2, 2026, this Court

dismissed Rodriguez’s complaint under Federal Rule of Civil Procedure 8(a) because it was

“largely unintelligible and fail[ed] to assert any factual or legal basis for relief.” Dkt. 4. The Court

instructed Rodriguez that any amended complaint must “(1) allege facts that clearly identify the

subject of this action, (2) connect those facts to the legal claims asserted, (3) separate each legal

claim into different paragraphs that connect the relevant facts to that claim, and (4) set out this

Court’s jurisdiction over the claims brought.” Id. at 2. Harris has moved to dismiss Rodriguez’s

amended complaint for, among other reasons, failing to comply with the Court’s instructions and

for lack of subject matter jurisdiction. Def.’s Mot. to Dismiss, Dkt. 12. The Court agrees and will

grant Harris’s motion to dismiss.

Complaints by pro se litigants are held to “less stringent standards than formal pleadings

drafted by lawyers.” Haines v. Kerner, 404 U.S. 519, 520 (1972). Even a pro se litigant, however, must comply with the Federal Rules of Civil Procedure. Jarrell v. Tisch, 656 F. Supp. 237, 239

(D.D.C. 1987). “A complaint must contain sufficient factual matter, accepted as true, to ‘state a

claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting

Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The Court still struggles to discern

Rodriguez’s claims. As best the Court can tell, Rodriguez again appears to allege that Harris

conspired with the U.S. Postal Service “to commit multiple irrelevant denials/responses, through

mail fraud” that resulted in “irreparable harm of forced homelessness contributed to aggravated

manslaughter for over 4 years.” Am. Compl. 4. The amended complaint, however, continues to

fail to specifically allege (1) the facts supporting these allegations or (2) the nature of the legal

claims. Because the Rule 8 standard has not been met, Harris has not received fair notice of the

claims being asserted or the basis for those claims, and thus cannot prepare an adequate response.

See Brown v. Califano, 75 F.R.D. 497, 498 (D.D.C. 1977). And “[i]f a plaintiff has been given

ample opportunity to comply with Rule 8 but fails to do so, or if the amended pleading suffers

from similar insufficiencies, then it is appropriate for the Court to dismiss the case without

providing another opportunity to amend.” Jiggetts v. District of Columbia, 319 F.R.D. 408, 414

(D.D.C. 2017).

The Court also agrees with Harris that it lacks subject matter jurisdiction and thus will

separately dismiss the case under Rule 12(b)(1). A complaint that lacks “an arguable basis either

in law or in fact” is “frivolous,” Neitzke v. Williams, 490 U.S. 319, 325 (1989), and the Court

cannot exercise subject matter jurisdiction over a frivolous complaint, Hagans v. Lavine, 415 U.S.

528, 536 (1974) (“Over the years, this Court has repeatedly held that the federal courts are without

power to entertain claims otherwise within their jurisdiction if they are ‘so attenuated and

unsubstantial as to be absolutely devoid of merit.’”) (quoting Newburyport Water Co. v.

Newburyport, 193 U.S. 561, 579 (1904)); Tooley v. Napolitano, 586 F.3d 1006, 1010 (D.C. Cir.

2009). Consequently, the Court is obligated to dismiss a complaint as frivolous when, as here,

“the facts alleged rise to the level of the irrational or the wholly incredible,” Denton v. Hernandez,

504 U.S. 25, 33 (1992), or “postulat[e] events and circumstances of a wholly fanciful kind,” Crisafi

v. Holland, 655 F.2d 1305, 1307-08 (D.C. Cir. 1981). To the extent the Court can understand the

gravamen of Rodriguez’s complaint, her allegations about a conspiracy between the Clerk of the

Supreme Court and the U.S. Postal Service to cause her homelessness and commit manslaughter

qualify as “irrational or wholly incredible.” Denton, 504 U.S. at 33. Accordingly, the Court will

also grant Harris’s motion to dismiss for lack of jurisdiction under Rule 12(b)(1).

Although the Court will dismiss the complaint and the action, it does so without prejudice,

so Rodriguez can still “correct[] the complaint’s defects and fil[e] a new lawsuit.” Ciralsky v. CIA,

355 F.3d 661, 671 (D.C. Cir. 2004).

CONCLUSION

For the reasons stated, the defendant’s motion to dismiss, Dkt. 12, is granted. A separate

order consistent with this decision accompanies this memorandum opinion.

DABNEY L. FRIEDRICH

August 28, 2026 United States District Judge