UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
) KENESHA LATTIMORE, ) ) Plaintiff, ) ) v. ) Civil Action No. 1:25-cv-04266 (UNA) ) MUNICIPALITY OF COLUMBUS, et al., ) ) Defendants. ) ___________________________________ )
MEMORANDUM OPINION
This matter is before the Court on review of Plaintiff’s Application for Leave to Proceed
in forma pauperis (“IFP”), ECF No. 2, and her pro se Complaint (“Compl.”), ECF No. 1. The
Court grants the IFP Application, and for the reasons explained below, it dismisses the complaint,
and this matter, without prejudice.
Plaintiff, a resident of Columbus, Ohio, sues the Municipality of Columbus, and a judge of
this district court. The Complaint’s allegations are wide-ranging, consisting of an assortment of
various alleged wrongdoing, by numerous alleged bad actors, in violation of the constitution and
the “Federalist Papers,” spanning approximately six years, borne from a nefarious conspiracy. See
generally Compl. At root, Plaintiff challenges the outcome of child-custody decisions made by
the local Ohio Franklin County courts and Franklin County Children Services. She demands
equitable relief and damages. See id. at 3, 5–9, 11, 13, 15–16, 19–20, 22, 26, 28, 30–32, 36, 39.
First, 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 falls short of compliance
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 is neither short nor plain, see Fed. R. Civ. P. 8(a), the allegations
cannot be described as simple, concise, and direct, see Fed. R. Civ. P. 8(d)(1), and the paragraphs
are not limited to a single set of circumstances, see Fed. R. Civ. P. 10(b). As here, courts
commonly dismiss complaints that contain bloated and disorganized allegations that violate Rule
8(a). See Spence v. U.S. Dep’t of Vet. Affairs, No. 19-cv-1947, 2022 WL 3354726, at *11 (D.D.C.
Aug. 12, 2022) (collecting cases); see also Jiggetts v. Dist. of Columbia, 319 F.R.D. 408, 413
(D.D.C. 2017) (When, as here, a pleading “contains an untidy assortment of claims that are neither
plainly nor concisely stated,” it does not fulfill the requirements of Rule 8), aff’d sub nom. Cooper
v. Dist. of Columbia, No. 17-7021, 2017 WL 5664737 (D.C. Cir. Nov. 1, 2017).
Here, Plaintiff’s belief in an ongoing conspiracy against her is supported only by
“threadbare recitals” and by “mere conclusory statements,” which is insufficient. See Iqbal, 556
U.S. at 678. A complaint “must plead ‘factual matter’ that permits the court to infer ‘more than
the mere possibility of [defendant’s] misconduct.’” Atherton v. District of Columbia Office of the
Mayor, 567 F.3d 672, 681–82 (D.C. Cir. 2009) (quoting Iqbal, 556 U.S. at 678–79; see
Aktieselskabet AF 21. Nov.2001 v. Fame Jeans, Inc., 525 F.3d 8, 16 n.4 (D.C. Cir. 2008) (“We
have never accepted ‘legal conclusions cast in the form of factual allegations’ because a complaint
needs some information about the circumstances giving rise to the claims.”) (quoting Kowal v. MCI Commc’ns Corp., 16 F.3d 1271, 1276 (D.C. Cir. 1994)). And dismissal is authorized whether
the claims are “based on an outlandish legal theory or on a close but ultimately unavailing one.”
Neitzke v. Williams, 490 U.S. 319, 327 (1989); see also Baker v. Dir., U.S. Parole Comm’n, 916
F.2d 725, 727 (D.C. Cir. 1990) (per curiam) (authorizing sua sponte dismissal for failure to state
a claim).
Second, and even if Plaintiff could overcome the pleading hurdles described above, she
has failed to establish subject matter jurisdiction. See generally 28 U.S.C. §§ 1331 and 1332.
Federal district courts generally lack jurisdiction to review or otherwise interfere with judicial
decisions made by state and local courts, and Plaintiff cannot circumvent that prohibition by
bringing this matter under the auspices of federal legal authority or against a federal defendant, or
by otherwise seeking such relief circuitously. See Richardson v. District of Columbia Court of
Appeals, 83 F.3d 1513, 1514 (D.C. Cir. 1996) (citing District of Columbia v. Feldman, 460 U.S.
462, 476 (1983) and Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923)). As here, a lawsuit is
considered a collateral attack “if, in some fashion, it would overrule a previous judgment[,]” Stone
v. HUD, 859 F. Supp. 2d 59, 64 (D.D.C. 2012) (quoting 37 Associates, Tr. for the 37 Forrester
St., SW Trust v. REO Const. Consultants, Inc., 409 F. Supp. 2d 10, 14 (D.D.C. 2006)), and
“questions the validity of a judgment or order in a separate proceeding that is not intended to obtain
relief from the judgment[,]” 37 Associates v. REO Constr. Consults., Inc., 409 F. Supp. 2d 10, 14
(D.D.C. 2006) (quoting In re Am. Basketball League, Inc., 317 B.R. 121, 128 (2004)).
Indeed, the domestic relations exception deprives a federal district court of the power to
issue or modify child custody decrees, Ankenbrandt v. Richards, 504 U.S. 689, 703 (1992), or to
decide child support obligations or custody determinations, see Bennett v. Bennett, 682 F.2d 1039,
1042 (D.C. Cir.
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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
) KENESHA LATTIMORE, ) ) Plaintiff, ) ) v. ) Civil Action No. 1:25-cv-04266 (UNA) ) MUNICIPALITY OF COLUMBUS, et al., ) ) Defendants. ) ___________________________________ )
MEMORANDUM OPINION
This matter is before the Court on review of Plaintiff’s Application for Leave to Proceed
in forma pauperis (“IFP”), ECF No. 2, and her pro se Complaint (“Compl.”), ECF No. 1. The
Court grants the IFP Application, and for the reasons explained below, it dismisses the complaint,
and this matter, without prejudice.
Plaintiff, a resident of Columbus, Ohio, sues the Municipality of Columbus, and a judge of
this district court. The Complaint’s allegations are wide-ranging, consisting of an assortment of
various alleged wrongdoing, by numerous alleged bad actors, in violation of the constitution and
the “Federalist Papers,” spanning approximately six years, borne from a nefarious conspiracy. See
generally Compl. At root, Plaintiff challenges the outcome of child-custody decisions made by
the local Ohio Franklin County courts and Franklin County Children Services. She demands
equitable relief and damages. See id. at 3, 5–9, 11, 13, 15–16, 19–20, 22, 26, 28, 30–32, 36, 39.
First, 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 falls short of compliance
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 is neither short nor plain, see Fed. R. Civ. P. 8(a), the allegations
cannot be described as simple, concise, and direct, see Fed. R. Civ. P. 8(d)(1), and the paragraphs
are not limited to a single set of circumstances, see Fed. R. Civ. P. 10(b). As here, courts
commonly dismiss complaints that contain bloated and disorganized allegations that violate Rule
8(a). See Spence v. U.S. Dep’t of Vet. Affairs, No. 19-cv-1947, 2022 WL 3354726, at *11 (D.D.C.
Aug. 12, 2022) (collecting cases); see also Jiggetts v. Dist. of Columbia, 319 F.R.D. 408, 413
(D.D.C. 2017) (When, as here, a pleading “contains an untidy assortment of claims that are neither
plainly nor concisely stated,” it does not fulfill the requirements of Rule 8), aff’d sub nom. Cooper
v. Dist. of Columbia, No. 17-7021, 2017 WL 5664737 (D.C. Cir. Nov. 1, 2017).
Here, Plaintiff’s belief in an ongoing conspiracy against her is supported only by
“threadbare recitals” and by “mere conclusory statements,” which is insufficient. See Iqbal, 556
U.S. at 678. A complaint “must plead ‘factual matter’ that permits the court to infer ‘more than
the mere possibility of [defendant’s] misconduct.’” Atherton v. District of Columbia Office of the
Mayor, 567 F.3d 672, 681–82 (D.C. Cir. 2009) (quoting Iqbal, 556 U.S. at 678–79; see
Aktieselskabet AF 21. Nov.2001 v. Fame Jeans, Inc., 525 F.3d 8, 16 n.4 (D.C. Cir. 2008) (“We
have never accepted ‘legal conclusions cast in the form of factual allegations’ because a complaint
needs some information about the circumstances giving rise to the claims.”) (quoting Kowal v. MCI Commc’ns Corp., 16 F.3d 1271, 1276 (D.C. Cir. 1994)). And dismissal is authorized whether
the claims are “based on an outlandish legal theory or on a close but ultimately unavailing one.”
Neitzke v. Williams, 490 U.S. 319, 327 (1989); see also Baker v. Dir., U.S. Parole Comm’n, 916
F.2d 725, 727 (D.C. Cir. 1990) (per curiam) (authorizing sua sponte dismissal for failure to state
a claim).
Second, and even if Plaintiff could overcome the pleading hurdles described above, she
has failed to establish subject matter jurisdiction. See generally 28 U.S.C. §§ 1331 and 1332.
Federal district courts generally lack jurisdiction to review or otherwise interfere with judicial
decisions made by state and local courts, and Plaintiff cannot circumvent that prohibition by
bringing this matter under the auspices of federal legal authority or against a federal defendant, or
by otherwise seeking such relief circuitously. See Richardson v. District of Columbia Court of
Appeals, 83 F.3d 1513, 1514 (D.C. Cir. 1996) (citing District of Columbia v. Feldman, 460 U.S.
462, 476 (1983) and Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923)). As here, a lawsuit is
considered a collateral attack “if, in some fashion, it would overrule a previous judgment[,]” Stone
v. HUD, 859 F. Supp. 2d 59, 64 (D.D.C. 2012) (quoting 37 Associates, Tr. for the 37 Forrester
St., SW Trust v. REO Const. Consultants, Inc., 409 F. Supp. 2d 10, 14 (D.D.C. 2006)), and
“questions the validity of a judgment or order in a separate proceeding that is not intended to obtain
relief from the judgment[,]” 37 Associates v. REO Constr. Consults., Inc., 409 F. Supp. 2d 10, 14
(D.D.C. 2006) (quoting In re Am. Basketball League, Inc., 317 B.R. 121, 128 (2004)).
Indeed, the domestic relations exception deprives a federal district court of the power to
issue or modify child custody decrees, Ankenbrandt v. Richards, 504 U.S. 689, 703 (1992), or to
decide child support obligations or custody determinations, see Bennett v. Bennett, 682 F.2d 1039,
1042 (D.C. Cir. 1982) (explaining that domestic relationship exception divests federal court of jurisdiction over “grant[ing] a divorce, determin[ing] alimony or support obligations, or
resolv[ing] parental conflicts over the custody of their children”). These types of determinations
must be contested in the local courts where the proceedings were held. See Lassiter v. Department
of Social Services, 452 U.S. 18, 25 (1981); see also Bennett, 682 F.2d at 1042 (child custody issues
uniquely suited to resolution in local courts).
Third, the Court finds no basis in Plaintiff’s allegations against the Defendant district judge.
Plaintiff alleges, without any explanation, that that Defendant “[k]new about alleged conspiracy
or rights violations, dismissed the filings as frivolous without proper review,” see Compl. at 3,
ostensibly disagreeing with the dismissal of Lattimore v. Gray, et al., No. 24-cv-03347 (UNA) by
that court, on February 3, 2025. However, Plaintiff has done nothing more than speculatively
question an unfavorable judicial decision without providing any credible basis for her challenge to
same. See Murchison v. Inter-City Mortg. Corp. Profit Sharing & Pension Plans, 503 F. Supp. 2d
184, 188 (D.D.C. 2007) (holding that judges must be alert to avoid the possibility that a litigant
would question the validity of a decision simply to avoid the consequences of and adverse
decision). Nor would filing a separate civil action be the proper avenue for such review, because
the Court generally lacks subject matter jurisdiction to review any of the decisions or actions of
another federal district court. See In re Marin, 956 F.2d 339 (D.C. Cir. 1992); Panko v. Rodak,
606 F. 2d 168, 171 n.6 (7th Cir. 1979), cert. denied, 444 U.S. 1081 (1980); United States v. Choi,
818 F. Supp. 2d 79, 85 (D.D.C. 2011) (citing Lewis v. Green, 629 F. Supp. 546, 553 (D.D.C.
1986)).
Moreover, the Defendant judge is absolutely immune from this lawsuit. See Sindram v.
Suda, 986 F.2d 1459, 1460 (D.C. Cir. 1993); see also Mireles v. Waco, 502 U.S. 9, 9 (1991); see
also Caldwell v. Kagan, 865 F. Supp. 2d 35, 42 (D.D.C. 2012) (“Judges have absolute immunity for any actions taken in a judicial or quasi-judicial capacity.”). He cannot be deprived of
immunity because an action he took was allegedly in error, malicious, or was in excess of his
authority. Stump v. Sparkman, 435 U.S. 349, 356 (1978); see also Mireles, 502 U.S. at 11
(“[J]udicial immunity is not overcome by allegations of bad faith or malice.”).
For all these reasons, the Complaint, ECF No. 1, and this case, are dismissed without
prejudice. Plaintiff’s other pending Motions, ECF Nos. 3, 4, 5, are all denied as moot. A separate
Order accompanies this Memorandum Opinion.
Date: March 6, 2026
Tanya S. Chutkan TANYA S. CHUTKAN United States District Judge