Arnold v. White House

• Court: District Court, District of Columbia
• Decided: June 17, 2025
• Docket: Civil Action No. 2025-1695
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

MARIE ENCAR ARNOLD,

Plaintiff,

v. Civil Action No. 25 - 1695 (LLA)

WHITE HOUSE, et al.,

Defendants.

MEMORANDUM OPINION

Plaintiff Marie Encar Arnold, proceeding pro se, filed a civil complaint against the White

House, the Executive Branch, and President Donald J. Trump in his official capacity. ECF No. 1.

For the reasons explained below, the court will dismiss the complaint and allow Ms. Arnold to file

an amended complaint that cures the existing deficiencies within thirty days.

I. FACTUAL BACKGROUND

In May 2025, Ms. Arnold filed a complaint against Defendants alleging violations of the

Federal Arbitration Act, 9 U.S.C. §§ 1 et seq., and seeking to compel Defendants to engage in a

settlement conference, see generally ECF No. 1. Her claims appear to relate to an administrative

claim for $10 billion that she filed under the Federal Tort Claims Act, 28 U.S.C. § 2671 et seq.

See generally ECF No. 1-1.

II. DISCUSSION

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). Rule 8(a) requires that a complaint include: (1) “a short and plain statement of the

grounds for the court’s jurisdiction”; (2) “a short and plain statement of the claim showing that the

pleader is entitled to relief”; and (3) “a demand for the relief sought.” Fed. R. Civ. P. 8(a)(1)-(3).

The rule ensures that defendants have “notice of what the . . . claim is and the grounds upon which

it rests.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 545 (2007). A complaint that is

“excessively long, rambling, disjointed, incoherent, or full of irrelevant and confusing material”

or one that “contains an untidy assortment of claims that are neither plainly or concisely stated,

nor meaningfully distinguished from bold conclusions, sharp harangues and personal comments”

does not meet Rule 8’s pleading standard. Jiggetts v. District of Columbia, 319 F.R.D. 408, 413

(D.D.C. 2017), aff’d sub nom. Cooper v. District of Columbia, No. 17-7021, 2017 WL 5664737

(D.C. Cir. Nov. 1, 2017) (quoting T.M. v. District of Columbia, 961 F. Supp. 2d 169, 174

(D.D.C. 2013)). A court may dismiss a complaint that fails to adhere to the requirements of Rule 8

either upon a motion or sua sponte. See Fed. R. Civ. P. 41(b); see also Ciralsky v. Cent. Intel.

Agency, 344 F.3d 661, 669 (D.C. Cir. 2004) (“Rule 41(b) authorizes the court to dismiss either a

claim or an action because of the plaintiff’s failure to comply with the Federal Rules . . . .”).

The court will sua sponte dismiss Ms. Arnold’s complaint because it fails to meet Rule 8’s

pleading standard. Specifically, the court cannot discern the substance of Ms. Arnold’s claims or

determine whether, if true, her allegations would entitle her to relief. See Brown v. Wash. Metro.

Area Transit Auth., 164 F. Supp. 3d 33, 35 (D.D.C. 2016). The court will, however, grant

Ms. Arnold leave to file an amended complaint that complies with Rule 8 within thirty days. Id.

III. CONCLUSION

For the foregoing reasons, the court will sua sponte dismiss Ms. Arnold’s complaint but

grant Ms. Arnold leave to file an amended complaint within thirty days.

2 LOREN L. ALIKHAN United States District Judge Date: June 17, 2025