Canales Cancel v. Department of Health and Human Resources

• Court: District Court, District of Columbia
• Decided: August 28, 2025
• Docket: Civil Action No. 2025-2294
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JOSÉ L. CANALES CANCEL, ) ) Plaintiff, ) ) v. ) Civil Action No. 25-2294 (UNA) ) DEPARTMENT OF HEALTH AND ) HUMAN RESOURCES, ) ) Defendant. )

MEMORANDUM OPINION

This matter is before the Court on initial review of Plaintiff’s application for leave to

proceed in forma pauperis, ECF No. 2, pro se complaint, ECF No. 1, and motion for

appointment of counsel, ECF No. 3. The Court will grant the application, dismiss the complaint

without prejudice, and deny the motion without prejudice as moot.

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). 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). It “does not

require detailed factual allegations, but it demands more than an unadorned, the-defendant-

unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quotations

omitted). In addition, Rule 8(d) states that “[e]ach allegation must be simple, concise, and

direct.” FED. R. CIV. P. 8(d)(1). “Taken together, [those provisions] underscore the emphasis

1 placed on clarity and brevity by the federal pleading rules.” Ciralsky v. CIA, 355 F.3d 661, 669

(D.C. Cir. 2004) (cleaned up). The Rule 8 standard ensures that defendants receive fair notice of

the claim being asserted so that they can prepare a responsive answer, mount an adequate

defense, and determine whether the doctrine of res judicata applies. See Brown v. Califano, 75

F.R.D. 497, 498 (D.D.C. 1977).

As drafted, the complaint fails to meet the minimal pleading standard set forth in Rule

8(a). It rambles from topic to topic without managing to articulate a viable legal claim, support

for his demand for “$250,000.00 indemnization,” Compl. at 11, and provide defendant with

adequate notice of the claim(s) brought against it. The Court, therefore, will dismiss the

complaint without prejudice.

A separate order will issue.

/s/ JIA M. COBB United States District Judge DATE: August 28, 2025