Jarman v. West Valley City Police Department

District Court, District of Columbia·Decided November 24, 2025·No. Civil Action No. 2025-3705·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

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

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Related

Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Ciralsky v. Central Intelligence Agency
355 F.3d 661 (D.C. Circuit, 2004)
Brown v. Califano
75 F.R.D. 497 (District of Columbia, 1977)
Jo Spence v. DVA
109 F.4th 531 (D.C. Circuit, 2024)