Cabrera v. London Africa Ltd

• Court: District Court, District of Columbia
• Decided: January 21, 2026
• Docket: Civil Action No. 2025-4032
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

VINCENT CABRERA,

Plaintiff,

v. Civil Action No. 25 - 4032 (UNA)

LONDON AFRICA LTD,

Defendant.

MEMORANDUM OPINION

This matter is before the court on Plaintiff Vincent Cabrera’s application to proceed in

forma pauperis, ECF No. 2, and pro se complaint, ECF No. 1. For the reasons explained below,

the court will grant Mr. Cabrera’s application and dismiss the complaint without prejudice.

Complaints filed by pro se litigants are held to “less stringent standards” than those applied

to pleadings drafted by lawyers. Haines v. Kerner, 404 U.S. 519, 520 (1972) (per curiam). Still,

pro se litigants must comply with the Federal Rules of Civil Procedure. Jarrell v. Tisch, 656 F.

Supp. 237, 239 (D.D.C. 1987). Rule 8(a) of the Federal Rules of Civil Procedure requires that a

complaint contain a short and plain statement of the grounds upon which the court’s jurisdiction

depends, a short and plain statement of the claim showing that the pleader is entitled to relief, and

a demand for judgment for the relief the pleader seeks. Fed. R. Civ. P. 8(a).

Mr. Cabrera’s complaint contains only two factual allegations: “Slave trade through Puerto

[R]ico” and “Mental health issues,” ECF No. 1, at 4, and Mr. Cabrera fails to demand relief of any

kind, see id. at 4-5. As drafted, the complaint falls far short of Rule 8’s minimal pleading standard. Accordingly, the court will grant Mr. Cabrera’s application to proceed in forma pauperis, ECF

No. 2, and dismiss the complaint without prejudice, ECF No. 1. A contemporaneous order will

issue.

LOREN L. ALIKHAN United States District Judge Date: January 21, 2026