Jarman v. West Valley City Police Department

• Court: District Court, District of Columbia
• Decided: November 24, 2025
• Docket: Civil Action No. 2025-3705
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

MICHAEL DEAN JARMAN, ) ) Plaintiff, ) v. ) Civil Action No. 25-3705 (UNA) ) WEST VALLEY CITY POLICE ) DEPARTMENT, et al., ) ) Defendants. )

MEMORANDUM OPINION

Rule 8(a) requires that a pleading “contain . . . a short and plain statement of the claim

showing that the pleader is entitled to relief.” FED. R. CIV. P. 8(a)(2); see Ashcroft v. Iqbal, 556

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

does not require a short and plain complaint, but rather a short and plain statement of the claim.”

Middlebrooks v. St. Coletta of Greater Washington, Inc., No. 09-cv-1281 (ESH), 2009 WL

3163061, at *1 (D.D.C. Sept. 30, 2009) (quoting Ciralsky, 355 F.3d at 670) (cleaned up)

(emphasis in original). In addition, Rule 8(d) requires that “[e]ach averment of a pleading shall

be simple, concise, and direct.” FED. R. CIV. P. 8(d)(1). “Taken together, [these provisions]

underscore the emphasis placed on clarity and brevity by the federal pleading rules.” Ciralsky,

355 F.3d at 668–69 (quoting In re Westinghouse Sec. Litig., 90 F.3d 696, 702 (3d Cir. 1996)

(quoting 5 Wright & Miller § 1217, at 169 (2d ed. 1990))).

The instant complaint, notwithstanding its extraordinarily length (ECF No. 1, at 418

pages), fails to set forth a short and plain statement of claim showing plaintiff’s entitlement to

relief from any defendant. Instead, the complaint only manages to “contain[] an untidy

assortment of claims that are neither plainly nor concisely stated, nor meaningfully distinguished

1 from bold conclusions, sharp harangues and personal comments,” Brown v. Califano, 75 F.R.D.

497, 499 (D.D.C. 1977), rendering it subject to dismissal. In short, the complaint is “too

unwieldy to proceed,” Spence v. U.S. Dep’t of Veterans Affairs, No. 19-cv-1947, 2022 WL

3354726, at *11 (D.D.C. Aug. 12, 2022), aff’d, 109 F.4th 531 (D.C. Cir. 2024), and in its current

form “is so confusing that a defendant cannot be expected to frame a response” to it. Brown v.

Dalton, No. 96-5285, 1997 WL 362505, at *1 (D.C. Cir. May 5, 1997) (per curiam) (citations

omitted).

An Order is issued separately.

TREVOR N. McFADDEN Date: November 24, 2025 United States District Judge