Garland v. Government of the District of Columbia

• Court: District Court, District of Columbia
• Decided: February 6, 2026
• Docket: Civil Action No. 2026-0087
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

LEON GARLAND,

Plaintiff, Civil Action No. 26-00087 (AHA) v.

GOVERNMENT OF THE DISTRICT OF COLUMBIA,

Defendant.

Memorandum Opinion

Leon Garland sues the District of Columbia alleging he was injured while working for the

District and seeking damages. ECF No. 1 at 4. On review of Garland’s complaint, the court

concludes it cannot be brought in federal court and dismisses for lack of subject matter jurisdiction.

To proceed in federal court, a plaintiff’s complaint must plausibly establish federal subject

matter jurisdiction. See Shuler v. United States, 531 F.3d 930, 932 (D.C. Cir. 2008). In considering

whether the complaint does so, the court must “assume the truth of all material factual allegations

in the complaint and ‘construe the complaint liberally, granting plaintiff the benefit of all

inferences that can be derived from the facts alleged,’ and upon such facts determine jurisdictional

questions.” Am. Nat’l Ins. Co. v. FDIC, 642 F.3d 1137, 1139 (D.C. Cir. 2011) (citations omitted).

Because Garland is proceeding pro se, the court is careful to give extra leeway, evaluating the

complaint “in light of all filings.” Ho v. Garland, 106 F.4th 47, 50 (D.C. Cir. 2024) (quotation

marks omitted) (quoting Brown v. Whole Foods Mkt. Grp., Inc., 789 F.3d 146, 152 (D.C. Cir.

2015)). However, “[i]f the court determines at any time that it lacks subject-matter jurisdiction, the

court must dismiss the action.” Fed. R. Civ. P. 12(h)(3). Garland appears to assert a personal injury claim against the District under D.C. law and

relies on diversity jurisdiction to bring it in federal court rather than in D.C. Superior Court.

However, the complaint does not plausibly establish diversity of citizenship. The diversity statute

gives federal courts jurisdiction over civil actions between citizens of different states where more

than $75,000 is in controversy. 28 U.S.C. § 1332(a)(1). Garland asserts diversity jurisdiction exists

because he is a Virginia citizen and the District is, well, in the District. ECF No. 1 at 3. But it is

well-established “the District is not subject to the diversity jurisdiction of the federal courts”

because it is not considered a “citizen” of a state. Long v. District of Columbia, 820 F.2d 409, 414

(D.C. Cir. 1987). Garland accordingly cannot establish diversity of citizenship on this basis.

Therefore, the court lacks subject matter jurisdiction over Garland’s complaint, although he can

likely sue in D.C. Superior Court.

For these reasons, the court dismisses Garland’s complaint without prejudice. A separate

order accompanies this memorandum opinion.

AMIR H. ALI United States District Judge

Date: February 6, 2026