E-Alert Case Updates
One-Paragraph Complaint Dismissed for Lack of Subject Matter Jurisdiction
Richardson v. Richardson, et al.
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:
(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.
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