Alter v. Federal Communications Commission

CourtDistrict Court, District of Columbia
DecidedMay 21, 2025
DocketCivil Action No. 2024-0745
StatusPublished

This text of Alter v. Federal Communications Commission (Alter v. Federal Communications Commission) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Alter v. Federal Communications Commission, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JOE ALTER,

Plaintiff, Civil Action No. 24-00745 (AHA) v.

FEDERAL COMMUNICATIONS COMMISSION,

Defendant.

Memorandum Opinion

Plaintiff Joe Alter filed this pro se suit against the Federal Communications Commission

(FCC), asserting the agency has a duty to prevent Fox News from spreading misinformation and

has violated that duty by not revoking the network’s broadcasting licenses. The FCC moves to

dismiss the complaint, arguing that this Court lacks subject-matter jurisdiction and that the

complaint fails to state a claim. The Court agrees that it lacks subject-matter jurisdiction to consider

Alter’s claims and grants the motion to dismiss.

I. Background1

Alter alleges that Fox News “seems to engage in a particularly egregious trafficking of

politically motivated lies and misinformation” that is “specifically designed to manipulate the

outcomes of US elections.” ECF No. 1 ¶ 5. Fox’s tactics have “caused the country at large great

harm” by “tampering with American’s [sic] ability to get accurate information.” Id. ¶¶ 8, 9. Alter

1 As required at the pleading stage, the Court accepts the complaint’s well-pled factual allegations and draws all reasonable inferences in Alter’s favor. Banneker Ventures, LLC v. Graham, 798 F.3d 1119, 1129 (D.C. Cir. 2015). asserts that the FCC has an obligation to protect the American people by “pulling Fox New’s [sic]

license.” Id. ¶ 9. He asks this Court to “[c]ompel the FCC to revoke Fox Corps broadcasting

licenses immediately until they can put a plan into place to correct the damage” and, in support of

that goal, seeks discovery into the “false programming to convey a political narrative that [Fox]

continue[s] to this day.” Id. ¶¶ 18, 19. The FCC has moved to dismiss for lack of subject-matter

jurisdiction under Federal Rule of Civil Procedure 12(b)(1) and failure to state a claim under

Federal Rule of Civil Procedure 12(b)(6).

II. Legal Standard

To survive dismissal under Rule 12(b)(1), a plaintiff must show that the Court has subject-

matter jurisdiction to hear their claim. See Shuler v. United States, 531 F.3d 930, 932 (D.C. Cir.

2008). Where, as here, there is no diversity jurisdiction, this includes showing that “federal law

creates the cause of action or that the plaintiff’s right to relief necessarily depends on resolution of

a substantial question of federal law.” Empire Healthchoice Assurance, Inc. v. McVeigh, 547 U.S.

677, 690 (2006) (citation omitted). It also includes showing that the plaintiff has standing to pursue

that federal question. Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). “To establish Article

III standing, the plaintiff must have ‘suffered an injury in fact’ that ‘is fairly traceable to the

challenged action of the defendant’ and it must be ‘likely, as opposed to merely speculative, that

the injury will be redressed by a favorable decision.’” Banner Health v. Price, 867 F.3d 1323,

1333–34 (D.C. Cir. 2017) (quoting Friends of the Earth v. Laidlaw Env’tl. Servs., 528 U.S. 167,

180–81 (2000)). “Setting ‘mere conclusory statements’ aside, the complaint must contain

‘sufficient factual matter, accepted as true,’ to support an inference of standing ‘that is plausible

on its face.’” Air Excursions LLC v. Yellen, 66 F.4th 272, 277 (D.C. Cir. 2023) (quoting Ashcroft

v. Iqbal, 556 U.S. 662, 678 (2009)).

2 III. Discussion

Although Alter’s complaint does not identify a cause of action, the Court is mindful of its

obligation to construe pro se complaints liberally. See Toolasprashad v. Bureau of Prisons, 286

F.3d 576, 583 (D.C. Cir. 2002). Alter alleges that “FCC’s regulations are discretionary” and “are

therefore reviewable by the court for abuse due to action or inaction.” ECF No. 1 ¶ 12. And, as a

remedy, he asks this Court to compel the FCC “to revoke Fox Corps broadcasting licenses.” Id.

¶ 18. The Court accordingly understands Alter to assert a challenge to the FCC’s decision to grant

or fail to revoke a license. As explained below, however, this Court lacks jurisdiction over such a

claim, both because this Court cannot review FCC orders related to licensing and because Alter

has not shown standing to assert the claim.

A. This Court Lacks Jurisdiction To Review FCC Licensing Decisions.

Congress designed a specific process for judicial review of FCC decisions, including those

related to licensing, and that process channels review to the courts of appeals generally or to the

D.C. Circuit specifically, not this Court. Section 402 of the Communications Act “describes two

mutually exclusive channels for the review of FCC decisions.” Vernal Enters., Inc. v. FCC, 355

F.3d 650, 655 (D.C. Cir. 2004). First, § 402(a) addresses actions to “enjoin, set aside, annul, or

suspend” FCC orders and provides that such actions “shall be brought as provided by and in the

manner prescribed in” the Hobbs Act. 47 U.S.C. § 402(a). That Act, in turn, provides that courts

of appeal have “exclusive jurisdiction to enjoin, set aside, suspend (in whole or in part), or to

determine the validity of” orders made reviewable by § 402(a). 28 U.S.C. § 2342(1). Second,

§ 402(b) allows parties to appeal FCC decisions and orders to the D.C. Circuit in enumerated

situations, including several that “involve the Commission’s licensing authority.” Vernal Enters.,

355 F.3d at 655 (citing 47 U.S.C. § 402(b)); see also PSSI Glob. Servs., L.L.C. v. FCC, 983 F.3d

1, 6 (D.C. Cir. 2020).

3 Alter’s claim appears to fit most naturally within § 402(b), which permits an appeal by a

“person who is aggrieved or whose interests are adversely affected by any order of the Commission

granting or denying” a station license. 47 U.S.C. § 402(b)(6). But no matter which of the two routes

to judicial review applies, this Court cannot exercise jurisdiction. See FCC v. ITT World

Commc’ns, Inc., 466 U.S. 463, 468 (1984) (explaining that under § 402(a), “[e]xclusive

jurisdiction for review of final FCC orders . . . lies in the Court of Appeals” and “[l]itigants may

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