Carrington v. Trump

• Court: District Court, District of Columbia
• Decided: November 25, 2025
• Docket: Civil Action No. 2025-3575
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

THEODORE MACON CARRINGTON, JR., ) ) Plaintiff, ) ) v. ) Civil Action No. 25-3575 (UNA) ) DONALD J. TRUMP, et al., ) ) Defendants. )

MEMORANDUM OPINION

This matter is before the Court on plaintiff’s application to proceed in forma pauperis and

his pro se complaint. The application will be granted, and the complaint will be dismissed

without prejudice for lack of subject matter jurisdiction.

“Article III of the United States Constitution limits the judicial power to deciding ‘Cases

and Controversies.’” In re Navy Chaplaincy, 534 F.3d 756, 759 (D.C. Cir. 2008) (quoting U.S.

Const. art. III, § 2). “One element of the case-or-controversy requirement is that plaintiffs must

establish that they have standing to sue.” Comm. on Judiciary of U.S. House of Representatives

v. McGahn, 968 F.3d 755, 762 (D.C. Cir. 2020) (en banc) (cleaned up). A party has standing for

purposes of Article III if he has “(1) suffered an injury in fact, (2) that is fairly traceable to the

challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial

decision.” Id. at 763 (quoting Lujan v. Defenders of Wildlife, 504 U.S. 555, 560 (1992)).

Plaintiff, a civilly committed detainee at the Federal Medical Center in Butner, North

Carolina, alleges that the current President of the United States “has orchestrated the biggest,

illegal power grab in the History of U.S. Elections[.]” Compl. at 6 (page numbers designated by

CM/ECF). He demands that the President “face criminal charges for his actions, and pay

[plaintiff] $75 billion dollars.” Id. at 11. Further, he demands payment of $75 billion from the 1 Attorney General of the United States, the United States Department of Justice, and the Federal

Elections Commission,” id., and his release from prison, see id.

Missing from the complaint are any factual allegations establishing that plaintiff

sustained (or is likely to sustain) an injury resulting from any defendant’s action. “[A] plaintiff

raising only a generally available grievance about government—claiming only harm to his and

every citizen’s interest in proper application of the Constitution and laws, and seeking relief that

no more directly and tangibly benefits him than it does the public at large—does not state an

Article III case or controversy.” Lujan, 504 U.S. at 573-74. Because plaintiff fails to allege facts

sufficient to establish standing, the Court lacks subject matter jurisdiction.

Insofar as plaintiff demands release from custody, this Court is not the proper forum for

adjudication of this habeas claim. The proper respondent in a habeas corpus action is plaintiff’s

custodian, see Rumsfeld v. Padilla, 542 U.S. 426, 434-35 (2004), and this “district court may not

entertain a habeas petition involving present physical custody unless the respondent custodian is

within its territorial jurisdiction,” Stokes v. U.S. Parole Comm’n, 374 F.3d 1235, 1239 (D.C. Cir.

2004).

An Order is issued separately.

TREVOR N. McFADDEN Date: November 24, 2025 United States District Judge