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One-Paragraph Complaint Dismissed for Lack of Subject Matter Jurisdiction

Richardson v. Richardson, et al.
No. 13-0868 (ABJ) (U.S. District Court for the District of Columbia June 19, 2013)

by Anna C. Horevay, Summer Associate
Semmes, Bowen & Semmes (

In Richardson v. Richardson, el al., the United States District Court for the District of Columbia considered sua sponte whether it had subject matter jurisdiction over a one (1)-paragraph complaint. The Court found that because the claim was patently insubstantial, it lacked subject matter jurisdiction and dismissed the action with prejudice.

Angelo Richardson, pro se, filed a one (1)-paragraph complaint to commence the action in District Court. Mr. Richardson later filed an amended complaint that also contained only a single paragraph, which read:

Plaintiff Angelo Richardson life were [sic] premeditated at birth at providence hospital, separated from his biological mother Neglected at birth ploted [sic] on with his identity brian [sic] wash with no legal document. Plaintiff Angelo Richardson request [sic] a subpoena with any of the three defendants to take a D.N.A test for proof and evident [sic] to ask question [sic] or information Why did the defendants premeditated [sic] Angelo Richardson life a [sic] birth, Why is the plot confidential, Plaintiff Angelo Richardson is separated from his biological mother, Samantha Grey.

(double underline in original). In response to the pleading, Defendant Eleanor Holmes Norton filed a motion to dismiss.

Before the Court would consider Ms. Nortonís motion, it first undertook a sua sponte review pursuant to FED. R. CIV. PRO. 12(h)(3) of whether it had subject matter jurisdiction in this case. As a federal trial court sitting in limited jurisdiction, the court was compelled to raise the issue because it could not act beyond its authority. The Court held that it lacked subject matter jurisdiction because the complaint was patently insubstantial and presented no federal question suitable for decision. While the Court noted that pro se litigants are typically afforded less stringent standards than those applied to pleadings drafted by lawyers, Mr. Richardson still failed to present a federal question suitable for decision by the Court. As a result, the Court dismissed this action with prejudice for lack of subject matter jurisdiction.