Adams v. United States of America

• Court: District Court, District of Columbia
• Decided: February 19, 2026
• Docket: Civil Action No. 2025-4346
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

MICHELLE LYNN ADAMS,

Plaintiff,

v. Civil Action No. 25 - 4346 (UNA)

UNITED STATES OF AMERICA, et al.,

Defendants.

MEMORANDUM OPINION

Michelle Lynn Adams, proceeding pro se, brings this action against the United States of

America and the U.S. Department of Justice, alleging that her 2010 bribery conviction in the

Eastern District of Virginia was “void from inception.” ECF No. 1, at 1-2, 4. She asks the court

to (1) declare that she is not a convicted felon and thus “entitled to exoneration as a matter of law”

because her conviction and the resulting forfeiture order are void; (2) enjoin Defendants from

relying on the conviction or forfeiture order; (3) order Defendants to account for all

forfeiture-related actions that rely on the allegedly void judgment; and (4) grant equitable relief

that restores her legal and property rights to the pre-conviction status quo. Id. at 8. Ms. Adams

has also filed a motion for leave to proceed in forma pauperis. ECF No. 2. For the following

reasons, the court will grant her motion to proceed in forma pauperis and dismiss her complaint

and the case for lack of subject-matter jurisdiction.

The court accepts the following facts from Ms. Adams’s complaint as true. From 2006 to

2010, she served as a federal contractor in Iraq and Afghanistan. ECF No. 1, at 2. Federal

prosecutors secured an indictment against her in September 2010 in the Eastern District of Virginia, and she was convicted and sentenced in December 2010. Id. at 3. Ms. Adams’s lawyer

did not “challenge . . . the indictment’s legal defects, the absence of any nexus between the alleged

offense and the forfeiture, or the internal inconsistencies reflected in the Presentence Investigation

Report.” Id. The sentencing court entered a $775,000 forfeiture order. Id. at 4. In forfeiture

proceedings, the government has treated one of Ms. Adams’s properties in Miami, Florida as

“reachable.” Id. During subsequent bankruptcy proceedings, Ms. Adams learned about purported

limitations on forfeiture related to bribery convictions. Id. at 6. She then worked with a paralegal

to identify “structural defects” in the indictment from her 2010 criminal case. Id.

In April 2025, Ms. Adams challenged her underlying conviction by filing a petition in the

Eastern District of Virginia for a writ of error coram nobis, id. at 7, which is an “extraordinary

remedy” allowing courts to “correct errors of fact . . . that affect the validity and regularity of [a]

judgment.” United States v. Lee, 84 F. Supp. 3d 7, 8-9 (D.D.C. 2015) (first alteration in original)

(quoting United States v. Morgan, 346 U.S. 502, 507 (1954)). The writ allows “the federal judge

who imposed a sentence . . . to set aside an underlying conviction and sentence which, for a valid

reason, should never have been entered.” United States v. Faison, 956 F. Supp. 2d 267, 269

(D.D.C. 2013) (quoting United States v. Hansen, 906 F. Supp. 688, 692 (D.D.C. 1995)).

Ms. Adams “has received no rulings, . . . hearings, [or] . . . substantive response from the

sentencing court, the Fourth Circuit [Court of Appeals], or the Department of Justice regarding the

merits” of her writ petition. ECF No. 1, at 7.

Ms. Adams’s case is an improper collateral attack on her sentence and conviction from the

Eastern District of Virginia. A lawsuit is a collateral attack if it requires “overrul[ing] the judgment

of [another] court.” Stone v. Holder, 859 F. Supp. 2d 48, 52 (D.D.C. 2012). This court “lacks

jurisdiction to review decisions of other federal courts.” Smalls v. United States, 471 F.3d 186,

2 192 (D.C. Cir. 2006). Although Ms. Adams has not filed a petition for a writ of coram nobis here,

the relief she seeks is effectively the same: she invokes the court’s equitable power and asks the

court to declare the sentencing court’s judgment void. ECF No. 1, at 8. To the extent Ms. Adams

intends to challenge her indictment, the resulting conviction, or the sentencing court’s forfeiture

order, she must do so through her pending action in the Eastern District of Virginia because “only

the court that imposed the sentence has jurisdiction to grant a writ of coram nobis.” Stoller v.

United States, 216 F. Supp. 3d 171, 175 (D.D.C. 2016); cf. Peoples v. U.S. Dep’t of Just.,

No. 24-CV-1017, 2024 WL 2015322, at *1 (D.D.C. May 6, 2024) (dismissing an action for lack

of jurisdiction because the incarcerated petitioner had challenged the validity of his indictment

from the Western District of New York and any remedy for the “collateral attack on his conviction”

was “in the sentencing court” through habeas proceedings).

For the foregoing reasons, the court will grant Ms. Adams’s Motion for Leave to Proceed

in Forma Pauperis, ECF No. 2, and dismiss her complaint, ECF No. 1, and the case for lack of

subject-matter jurisdiction. A contemporaneous order will issue.

LOREN L. ALIKHAN United States District Judge Date: February 19, 2026