Frederick v. Small Claims District Courthouse

• Court: District Court, District of Columbia
• Decided: May 14, 2026
• Docket: Civil Action No. 2026-0437
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

DARION FREDERICK, ) ) Plaintiff, ) ) v. ) Civil Action No. 1:26-cv-00437 (UNA) ) SMALL CLAIMS ) DISTRICT COURTHOUSE, et al., ) ) ) Defendants. )

MEMORANDUM OPINION This matter is currently before the Court on consideration of Plaintiff’s pro se Complaint

(“Compl.”), ECF No. 1, and his Application for Leave to Proceed in forma pauperis (“IFP”), ECF

No. 2. Upon review, the Court grants Plaintiff’s IFP Application, and for the reasons explained

below, it dismisses this matter without prejudice.

Plaintiff, a resident of Maryland, sues the “Small Claims District Courthouse,” located at

510 4th Street N.W., and three unnamed D.C. court employees. See Compl. at 1–2. He does not

provide names or addresses for the intended individual Defendants, in contravention of D.C. Local

Rule 5.1(c)(1); see Armstrong v. Bureau of Prisons, 976 F. Supp. 17, 23 (D.D.C. 1997) (“there is

no provision in the federal statutes or federal rules of civil procedure for the use of fictitious

defendants.”), aff’d, No. 97-5208, 1998 WL 65543 (D.C. Cir. Jan. 30, 1998) (per curiam), and

D.C. local courts are all non sui juris, see Sibley v. U.S. Supreme Court, 786 F. Supp. 2d 338, 344–

45 (D.D.C. 2011) (citing cases); Featherston v. Dist. of Columbia Sup. Court, No. 07-1933, 2009

WL 10713464, at *2 (D.D.C. May 5, 2009) (citing cases). Therefore, as pleaded, none of these

Defendants can be sued. The allegations themselves fare no better. Plaintiff broadly and vaguely contends that

Defendants were “ambiguously racist and fascist,” by denying him service. See id. at 4. He

demands anywhere from $500 million to $1 trillion in damages. See id. No other information,

context, or supporting details, are provided.

Pro se litigants must comply with the Federal Rules of Civil Procedure, Jarrell v. Tisch,

656 F. Supp. 237, 239 (D.D.C. 1987), and here, the Complaint fails to comply with Rule 8(a) of

the Federal Rules of Civil Procedure, which requires a pleading to contain “(1) a short and plain

statement of the grounds for the court’s jurisdiction [and] (2) a short and plain statement of the

claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a); see Ashcroft v. Iqbal, 556

U.S. 662, 678–79 (2009); Ciralsky v. CIA, 355 F.3d 661, 668–71 (D.C. Cir. 2004). The Rule 8

standard ensures that defendants receive fair notice of the claim being asserted so that they can

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).

The instant Complaint does not provide the Defendants or the Court with adequate notice

of a claim. As here, “the court need not accept inferences drawn by plaintiff[] if such inferences

are unsupported by the facts set out in the complaint.” Kowal v. MCI Commc’ns Corp., 16 F.3d

1271, 1276 (D.C. Cir. 1994). Nor must the court accept “a legal conclusion couched as a factual

allegation,” or “naked assertions devoid of further factual enhancement.” Ashcroft v. Iqbal, 556

U.S. 662, 678 (2009) (internal quotation marks omitted). “Threadbare recitals of the elements of

a cause of action, supported by mere conclusory statements,” are not sufficient to state a claim. Id.

Accordingly, this case is dismissed without prejudice. A separate Order accompanies this

Memorandum Opinion.

DATE: May 14, 2026 /s/ CHRISTOPHER R. COOPER United States District Judge