Michalapoulos v. Schiff

• Court: District Court, District of Columbia
• Decided: May 13, 2026
• Docket: Civil Action No. 2026-1139
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

ST. STEFAN MICHALOPOULOS,

Plaintiff, Case No. 26-cv-1139 (JMC)

v.

SENATOR ADAM SCHIFF,

Defendant.

MEMORANDUM OPINION

Pro se Plaintiff St. Stefan Michalopoulos filed a civil complaint against United States

Senator Adam Schiff. For the reasons discussed below, the Court DISMISSES the complaint for

failure to comply with Federal Rule of Civil Procedure 8(a)(2).

Federal Rule of Civil Procedure 8(a)(2) requires civil complaints to include “a short and

plain statement of the claim showing that the pleader is entitled to relief.” It does not demand

“detailed factual allegations,” but it does require enough factual information “to raise a right to

relief above the speculative level.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007).

These procedural requirements promote fairness in litigation—Rule 8(a) is intended to “give the

defendant fair notice of what the . . . claim is and the grounds upon which it rests.” Id. (citing

Conley v. Gibson, 355 U.S. 41, 47 (1957)). Pleadings filed by pro se litigants are held to less

stringent standards than those applied to formal pleadings drafted by lawyers. See Haines v.

Kerner, 404 U.S. 519, 520 (1972). But even pro se litigants must comply with the Federal Rules

of Civil Procedure.

Michalopoulos’s complaint does not satisfy these requirements. The complaint itself is 98

pages long, and it is accompanied by 460 pages of exhibits. See ECF 1; ECF 1-1. Near the

1 beginning of the complaint, Michalopoulos lists four “disputes for judicial resolution,” which

include “DOJ Investigators who got fired jobs back immediately,” “FBI + DOJ purges 1900

victims of ‘stupid bullshit’ jobs back immediately,” “Immigrations (A) grandfather 73,000 ex post

facto laws (B) criminal procedures immediately,” and “Initiate investigation for 5 impeachments

+ jail.” ECF 1 at 4. Michalopoulos goes on in the complaint to say, among many other things, that

his “case is criminal laws,” id. at 7, that a “Federal Cover Up Operation” is involved, id., and that

“this case is a Negligence case for Adam Schiff to not have these cases investigated by the HPSCI

Internal Affairs as required at this point as Donald Trump Conspiracies,” id. at 10. Even construing

the complaint liberally, the Court is unable to identify what cognizable harm Michalopoulos has

suffered, who caused him that harm, and how the law entitles him to any relief. The many notices

Michalopoulos has filed since filing his complaint do not clarify the complaint, either.

Michalopoulos’s complaint is therefore dismissed for failure to comply with Rule 8(a)(2).

The Court acknowledges that dismissing a case sua sponte is an unusual step, but the Court has

the authority to do so when plaintiffs fail to comply with procedural rules. See, e.g., Brown v.

WMATA, 164 F. Supp. 3d 33, 35 (D.D.C. 2016) (dismissing a complaint sua sponte for failing to

comply with Rule 8(a)); Hamrick v. United States, No. 10-cv-857, 2010 WL 3324721, at *1

(D.D.C. Aug. 24, 2010) (same); see also Ciralsky v. CIA, 355 F.3d 661, 668–69 (D.C. Cir.

2004) (finding no abuse of discretion where a district court dismissed a claim without prejudice

for failure to comply with Rule 8(a)).

The Court will grant Michalopoulos leave to refile within 30 days (i.e., by June 12, 2026)

an amended complaint that cures the existing deficiencies. If he does not file an amended complaint

within that timeframe, files an amended complaint that recycles the present complaint, or otherwise

fails to comply with Rule 8, this action may be dismissed with prejudice. Brown, 164 F. Supp. 3d

2 at 35. The Court also DENIES Michalopoulos’s motion for service, ECF 7, as moot. A separate

order accompanies this memorandum opinion.

SO ORDERED.

__________________________ JIA M. COBB United States District Judge

Date: May 13, 2026