Echenique v. Biden

• Court: District Court, District of Columbia
• Decided: March 27, 2025
• Docket: Civil Action No. 2025-0776
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IVETTE T. ECHENIQUE, ) ) Plaintiff, ) ) v. ) Civil Action No. 25-0776 (UNA) ) ) JOE BIDEN, et al., ) ) Defendants. )

MEMORANDUM OPINION

This matter is before the Court on review of plaintiff’s application to proceed in forma

pauperis and pro se civil complaint. The Court GRANTS the application and, for the reasons

stated below, DISMISSES the complaint and this civil action without prejudice.

The Court has reviewed plaintiff’s complaint, keeping in mind that complaints filed by

pro se litigants are held to less stringent standards than are applied to formal pleadings drafted by

lawyers. See Haines v. Kerner, 404 U.S. 519, 520 (1972). Even 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). The purpose of the minimum

standard of Rule 8 is to give fair notice to the defendants of the claim being asserted, sufficient to

prepare a responsive answer, to prepare an adequate defense and to determine whether the

doctrine of res judicata applies. Brown v. Califano, 75 F.R.D. 497, 498 (D.D.C. 1977). Plaintiff appears to hold the former President of the United States and others responsible

for all manner of harm, from discrimination to false arrest. The Court concludes that the

complaint, as amended, falls far short of the minimum pleading standard set forth in Rule 8(a). It

fails to allege facts sufficient to state a viable legal claim, or a credible basis for plaintiff’s

demand for $66 billion.

The Court GRANTS plaintiff’s application to proceed in forma pauperis (ECF Nos. 2, 4),

DISMISSES the complaint (ECF Nos. 1, 3) without prejudice, and DENIES plaintiff’s motions

(ECF Nos. 6-7) without prejudice as moot.

A separate order accompanies this Memorandum Opinion.

DATE: March 27, 2025 /s/ CHRISTOPHER R. COOPER United States District Judge