Leone v. State of Illinois

• Court: District Court, District of Columbia
• Decided: May 7, 2025
• Docket: Civil Action No. 2025-0846
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

CHRISTOPHER G. LEONE, ) ) Plaintiff, ) ) v. ) Civil Action No. 25-0846 (UNA) ) STATE OF ILLINOIS, et al., ) ) Defendants. )

MEMORANDUM OPINION

This matter is before the Court on initial review of plaintiff’s application for leave to

proceed in forma pauperis, ECF No. 2, and pro se complaint, ECF No. 1. The Court will grant

the application and dismiss the complaint without prejudice.

Complaints filed by pro se litigants are held to “less stringent standards” than those

applied to pleadings drafted by lawyers. Haines v. Kerner, 404 U.S. 519, 520 (1972). Still, pro

se litigants must comply with the Federal Rules of Civil Procedure. Jarrell v. Tisch, 656 F.

Supp. 237, 239 (D.D.C. 1987). Rule 8(a) of the Federal Rules of Civil Procedure requires that a

complaint contain a short and plain statement of the grounds upon which the court’s jurisdiction

depends, a short and plain statement of the claim showing that the pleader is entitled to relief,

and a demand for judgment for the relief the pleader seeks. FED. R. CIV. P. 8(a). It “does not

require detailed factual allegations, but it demands more than an unadorned, the-defendant-

unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quotations

omitted). In addition, Rule 8(d) states that “[e]ach allegation must be simple, concise, and

direct.” FED. R. CIV. P. 8(d)(1). “Taken together, [those provisions] underscore the emphasis

placed on clarity and brevity by the federal pleading rules.” Ciralsky v. CIA, 355 F.3d 661, 669

(D.C. Cir. 2004) (cleaned up). The Rule 8 standard ensures that defendants receive fair notice of

1 the claim being asserted so that they can prepare a responsive answer, mount an adequate

defense, and determine whether the doctrine of res judicata applies. See Brown v. Califano, 75

F.R.D. 497, 498 (D.D.C. 1977).

As drafted, the complaint fails to meet the minimal pleading standard set forth in Rule

8(a). It is a disorganized hodgepodge of assertions and citations to federal statutes and

procedural rules, and it fails to articulate a plausible legal claim. Most importantly, in its current

form, the complaint fails to provide Defendants with adequate notice of the claim(s) brought

against them and fails to provide the Court with adequate basis to determine whether it has

jurisdiction to consider Plaintiff’s claims. The Court, therefore, will dismiss the complaint

without prejudice.

A separate order will issue.

/s/ RANDOLPH D. MOSS United States District Judge DATE: May 7, 2025