Elmore v. Bank of America

• Court: District Court, District of Columbia
• Decided: January 2, 2026
• Docket: Civil Action No. 2025-2251
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

MATTHEW ROBERT ELMORE, ) ) Plaintiff, ) ) v. ) Civil Action No. 25-2251 (UNA) ) BANK OF AMERICA, ) ) Defendant. )

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 such that they might prepare a responsive

answer and an adequate defense and determine whether the doctrine of res

judicata applies. Brown v. Califano, 75 F.R.D. 497, 498 (D.D.C. 1977).

1 Plaintiff demands that Bank of America produce “all bank records since 1980 in all of

[plaintiff’s] names.” Compl. at 3; see id. at 4. Although plaintiff invokes federal question

jurisdiction, see id. at 3, it is unclear that a demand for records purportedly maintained by a

corporation amounts to a “civil action[] arising under the Constitution, laws, or treaties of the

United States,” 28 U.S.C. § 1331. Even if this were a matter over which this Court has

jurisdiction, the complaint fails to allege sufficient facts to put Bank of America on notice of

plaintiff’s claim, particularly because the complaint does not identify any other names by which

plaintiff is or was known.

As drafted, the complaint does not comply with Rule 8, and it will be dismissed. An

Order consistent with this Memorandum Opinion is issued separately.

DATE: January 2, 2026 /s/ ANA C. REYES United States District Judge