Klayman v. Kollar-Kotelly

CourtDistrict Court, District of Columbia
DecidedMarch 17, 2026
DocketCivil Action No. 2023-3773
StatusPublished

This text of Klayman v. Kollar-Kotelly (Klayman v. Kollar-Kotelly) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Klayman v. Kollar-Kotelly, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

LARRY ELLIOT KLAYMAN,

Plaintiff, Case No. 23-cv-3773 (JMC)

v.

COLLEEN KOLLAR-KOTELLY, HON.,

Defendant.

MEMORANDUM OPINION

Pro se Plaintiff Larry Klayman has sued a judge of this District, the Honorable Colleen

Kollar-Kotelly, over an order she issued which denied Klayman’s request to file documents

electronically in one of his cases. Klayman alleges that the order violated his constitutional rights.

As relief, Klayman seeks money damages against Defendant and an order from this Court that he

be allowed to file electronically in his cases before her. Defendant has moved to dismiss on various

grounds, including for lack of subject-matter jurisdiction and failure to state a claim. For the

reasons discussed below, the Court will GRANT Defendant’s motion to dismiss. 1

I. BACKGROUND

This lawsuit is one of many arising from an earlier civil lawsuit between Klayman and the

organization he founded in 1994, Judicial Watch. See Klayman v. Rao, 49 F.4th 550, 551 (D.C.

Cir. 2022) (discussing the history of the Judicial Watch case and Klayman’s associated lawsuits,

1 Unless otherwise indicated, the formatting of citations has been modified throughout this opinion, for example, by omitting internal quotation marks, emphases, citations, and alterations and by altering capitalization. All pincites to documents filed on the docket in this case are to the automatically generated ECF Page ID number that appears at the top of each page.

1 including prior lawsuits against Judge Kollar-Kotelly). Klayman eventually sued Judicial Watch,

and the case was assigned to Judge Kollar-Kotelly. 2 See Klayman v. Judicial Watch, Inc., 06-cv-

670 (D.D.C.). Over the course of the litigation, Klayman filed “numerous discovery and pretrial

motions, including five motions for Judge Kollar-Kotelly’s recusal.” Klayman v. Rao, No. 21-cv-

2473, 2021 WL 4948025, at *1 (D.D.C. Oct. 25, 2021), aff’d, 49 F.4th 550 (D.C. Cir. 2022); see

also ECF 1-1 ¶¶ 5, 8–9.

The local rules of this Court provide that a pro se party may obtain a “CM/ECF username

and password”—granting them the ability to file documents electronically rather than by mail or

in person—“with leave of Court.” LCvR 5.4(b)(2). “Whether leave of Court should be granted is

within the discretion of the judge to whom the case is assigned.” Id. On February 2, 2022, Klayman

filed a motion in the Judicial Watch case requesting that Judge Kollar-Kotelly grant him access to

file electronically. See Judicial Watch, 06-cv-670 (D.D.C.), ECF 639. Two days later, Judge

Kollar-Kotelly denied the request in a minute order, with the relevant portion reading as follows:

In his Motion, Plaintiff seeks “leave to file electronically” in this case. Pursuant to Local Rule of Civil Procedure 5.4(b), a “pro se party may obtain a CM/ECF user name and password from the Clerk with leave of Court.” The decision whether to grant the motion “is within the discretion of the judge to whom the case is assigned.” The Motion must describe the party’s access to the internet and certify that he “either has successfully completed the entire Clerk’s Office on-line tutorial or has been permitted to file electronically in other federal courts.” LCvR 5.4(b)(2). The Court DENIES WITHOUT PREJUDICE Plaintiff’s Motion. Plaintiff has demonstrated sufficient ability to file pleadings on the docket. Each of the Court’s Orders and Minute Orders in this case will specify that the Clerk shall mail a copy of the order to Plaintiff at his address of record. Defendants similarly must ensure that each filing is properly served upon Plaintiff in accordance with the Federal and Local Rules.

Judicial Watch, 06-cv-670 (D.D.C.), Feb. 4, 2022 Min. Order; ECF 1-1 ¶ 10.

2 The docket for the case indicates that the case was terminated in 2023, but Klayman has continued to file various post-judgment motions and notices through October 2025. See Klayman, 06-cv-670 (D.D.C.).

2 Klayman never renewed his request for electronic filing privileges. Instead, he filed a

complaint against Judge Kollar-Kotelly in the Superior Court for the District of Columbia, alleging

that she had violated his rights under the First and Fourteenth Amendments of the U.S.

Constitution, bringing his claim under Bivens v. Six Unknown Named Agents of Federal Bureau

of Narcotics, 403 U.S. 388 (1971). ECF 1-1 ¶¶ 22–34. Klayman states that Defendant had “no

rational explanation” for her decision and was “driven by a vindictive and irrational intent to

deprive” him “of the ability to participate meaningfully in the” Judicial Watch case. Id. ¶ 12.

Klayman requests money damages against Defendant as well as “injunctive and equitable relief”

in the form of an order “mandating that he be allowed to file electronically in all cases before her.”

ECF 1-1 ¶¶ 28, 34; id. at 7.

Defendant removed the case to this Court pursuant to 28 U.S.C. § 1442(a)(1), see ECF 1,

and has moved to dismiss on various grounds, including for lack of subject matter jurisdiction and

failure to state a claim, 3 ECF 6; ECF 9. Klayman opposes. ECF 8. The Court proceeds to address

the motion.

II. LEGAL STANDARD

Defendant first moves to dismiss for lack of subject-matter jurisdiction under Rule

12(b)(1). “Federal courts are courts of limited jurisdiction,” and it is generally “presumed that a

cause lies outside [of] this limited jurisdiction.” Kokkonen v. Guardian Life Ins. Co. of Am.,

511 U.S. 375, 377 (1994). If a court lacks subject matter jurisdiction to entertain a claim, it must

dismiss that claim. Fed. R. Civ. P. 12(h)(3). While pleadings by pro se litigants are generally “held

to less stringent standards than formal pleadings,” it is well-settled that a plaintiff, even one

3 Defendant also moved to dismiss on the ground that Klayman had failed to properly serve her. ECF 6 at 24–25. The Court need not address this basis for dismissal given that the Court dismisses the complaint on other grounds.

3 proceeding pro se, bears the burden of establishing jurisdiction. 4 Smith v. Scalia, 44 F. Supp. 3d.

28, 36 (D.D.C. 2014), aff’d, No. 14-5180, 2015 WL 13710107 (D.C. Cir. Jan. 14, 2015). As when

adjudicating a 12(b)(6) motion for failure to state a claim, the Court “must accept as true all of the

factual allegations in the complaint and draw all reasonable inferences in favor of the

plaintiff, . . . but it need not accept inferences unsupported by the facts alleged or legal conclusions

that are cast as factual allegations.” Id. at 35–36. However, when considering a motion to dismiss

for lack of jurisdiction, a court “must scrutinize the plaintiff’s allegations more closely” than it

would “under a motion to dismiss pursuant to Rule 12(b)(6).” Schmidt v. U.S. Capitol Police Bd.,

826 F. Supp. 2d 59, 65 (D.D.C. 2011). Sovereign immunity is “jurisdictional in nature,” FDIC v.

Meyer, 510 U.S. 471

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