Doe v. Administrative Office of the U.S. Courts

CourtDistrict Court, District of Columbia
DecidedApril 15, 2025
DocketCivil Action No. 2025-0701
StatusPublished

This text of Doe v. Administrative Office of the U.S. Courts (Doe v. Administrative Office of the U.S. Courts) 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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Doe v. Administrative Office of the U.S. Courts, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JANE DOE,

Plaintiff, Civil Action No. 25 - 701 (SLS) v. Judge Sparkle L. Sooknanan THE ADMINISTRATIVE OFFICE OF THE U.S. COURTS, et al.,

Defendants.

MEMORANDUM OPINION

Jane Doe is a pro se plaintiff who filed what the Court construes as a Complaint on

March 10, 2025. See Compl., ECF No. 1. On the same day, she filed a Motion for Leave to Proceed

in forma pauperis. See Pl.’s Mot. Leave, ECF No. 2. She has since filed several other motions,

including a Motion for Preliminary Injunction and a Motion for Temporary Restraining Order

(TRO), ECF No. 5; a Motion for Injunction and a Motion to Expedite Ruling, ECF No. 6;

an Emergency Motion for Summary Judgment, ECF No. 7; a Motion to Transfer, ECF No. 8;

an Emergency Motion for TRO, ECF No. 12; an Emergency Motion for Protective Order,

an Emergency Motion to Seal Documents, a Motion to Transfer, a Motion for Judicial

Intervention, a Motion for Immediate Relief, and a Motion for Sanctions, ECF No. 13; and

an Emergency Motion for TRO, a Motion to Transfer, an Emergency Motion for Protective Order,

a Motion to Expedite, a Motion to Disqualify a Judge, and a Motion for Sanctions, ECF No. 14.

The Court grants the Motion for Leave to Proceed in forma pauperis, ECF No. 2. But for the

following reasons, the Court dismisses the Complaint and denies the remaining motions as moot. BACKGROUND

Ms. Doe sues various officers and employees of the Administrative Office of the United

States Courts, the Judicial Conference of the United States, and the United States District Court

for the Eastern District of Virginia, all in their official capacities. See Compl. at 1. She also sues

the Administrative Office of the United States Courts and the Judicial Conference of the United

States. See id.1 Ms. Doe provides almost no factual background in her four-page Complaint.

She says that the Defendants “deliberately and knowingly inflicted harm” on her by “violating her

constitutional rights, obstructing her access to the courts, and causing severe emotional and

psychological distress through intentional misconduct.” Id. at 2. And she claims that they:

(1) “[p]ublicly expos[ed] [her] sensitive trauma and medical history, violating her right to

privacy”; (2) “[o]bstruct[ed] [her] access to the judicial system, leading to irreparable harm”;

(3) “retaliat[ed]” against [her] through procedural misconduct and clerk abuse”;

and (4) “engag[ed] in conduct that constitutes gross negligence, intentional infliction of emotional

distress, and violations of international human rights protections.” Id. She never clarifies who

exposed what trauma and medical history, or how it happened. She also claims that the Defendants

“engaged in . . . intentional torts,” including the intentional infliction of emotional distress by

exposing “private medical records”; gross negligence by “failing to follow basic judicial

procedures”; and obstruction of justice by denying “access to a fair tribunal.” Id. at 3.

1 The Defendants are the Administrative Office of the U.S. Courts; the Honorable Roslynn R. Mauskopf, in her official capacity as the Director of the Administrative Office of the U.S. Courts; the Judicial Conference of the United States; the Honorable Vanita Gupta, in her official capacity as the Chair of the Judicial Conference Committee on Rules of Practice and Procedure; the Honorable Ivan D. Davis, in his capacity as a United States Magistrate Judge; the Honorable Patricia Tolliver Giles, in her official capacity as a United States District Court Judge; Judith Lanham, in her official capacity as Clerk of Court; and Dana Van Metre, in her official capacity as Clerk of Court. See Compl. at 1.

2 A supplemental document attached to Ms. Doe’s Complaint provides no additional facts.

See generally Supp., ECF No. 1-1. But it does sort her claims into three categories. See id. at 1–2.

First, she alleges what she labels as constitutional and federal statutory claims, which include

“[v]iolations of Due Process,” “[v]iolations of Equal Protection,” “[i]ntentional deprivation of

access to the courts,” “[o]struction of justice,” and “[r]etaliatory misconduct against a pro se

litigant.” Id. Second, she alleges a few state law claims, including the intentional infliction of

emotional distress, gross negligence, and “[a]buse of [p]rocess.” Id. at 2. And third, she alleges

“international personal injury claims” under the Foreign Sovereign Immunities Act (FSIA). Id.

Ms. Doe’s request for relief asks the Court to “[a]ssert jurisdiction over this case”; “[h]old

that [the] Defendants are not entitled to absolute, qualified, or judicial immunity”; “[a]llow [certain

of the] Plaintiff’s [non-FSIA] claims to proceed”; “[r]ecognize [the] Plaintiff’s right to pursue

[FSIA claims]”; and “[g]rant any additional relief this Court deems just and necessary.” Id. at 5.

Some of these requests might be described as declaratory relief. But Ms. Doe also seems interested

in money damages and some form of injunctive relief. See Compl. at 2 (noting that Bivens v. Six

Unknown Agents, 403 U.S. 388 (1971) permits money damages, and citing Ex parte Young,

209 U.S. 123 (1908), suggesting an interest in injunctive relief).

DISCUSSION

The Court lacks subject matter jurisdiction over all of the claims it can identify in

Ms. Doe’s Complaint. Any claims for money damages are barred by sovereign immunity. And the

Court lacks the power to provide injunctive or declaratory relief that would act as a collateral attack

on another court’s proceedings. To the extent Ms. Doe is asking for other injunctive or declaratory

relief, such claims are dismissed sua sponte for failure to state a claim upon which relief can be

granted.

3 A. Subject Matter Jurisdiction

“We begin with the ‘first and fundamental question’ of subject-matter jurisdiction.”

Leopold v. Manger, 102 F.4th 491, 494 (D.C. Cir. 2024) (quoting Steel Co. v. Citizens for a Better

Env’t, 523 U.S. 83, 94 (1998)). “Federal district courts, as courts of limited jurisdiction, have a

sua sponte responsibility to ensure that they have jurisdiction to entertain a case.”

Schindler Elevator Corp. v. Wash. Metro. Area Transit Auth., 514 F. Supp. 3d 197, 202

(D.D.C. 2020) (citations omitted). “And if it is determined that the court does not have

subject-matter jurisdiction, it cannot afford plaintiffs any relief—injunctive or otherwise.” Id.

(citations omitted); see also McGinn, Smith & Co., Inc. v. Fin. Indus. Reg. Auth., 786 F. Supp. 2d

139, 145 (D.D.C. 2011) (“Before [a court] can reach the merits of [a plaintiff’s] request for a TRO,

the [c]ourt must ensure that it has subject matter jurisdiction over [the] action.”). “Accordingly,

‘[i]f the court determines at any time that it lacks subject matter jurisdiction, the court must dismiss

the action.’” Schindler Elevator Corp., 514 F. Supp. 3d at 202 (quoting Fed. R. Civ. P. 12(h)(3)).

“A federal court must presume that a cause of action lies outside its limited jurisdiction,

with ‘the burden of establishing the contrary’ resting upon the plaintiff.” Id. (quoting Kokkoken v.

Guardian Life Ins. Co.

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