Noha v. Washington Metropolitan Area Transit Authority

• Court: District Court, District of Columbia
• Decided: August 11, 2025
• Docket: Civil Action No. 2025-2362
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

OLHA NOHA, ) ) Plaintiff, ) ) v. ) Civil Action No. 25-2362 (UNA) ) ) WASHINGTON METROPOLITAN AREA ) TRANSIT AUTHORITY, et al., ) ) Defendants. )

MEMORANDUM OPINION

This matter is before the court on plaintiff’s application to proceed in forma pauperis, ECF

No. 2, and pro se complaint, ECF No. 1. The Court grants the application and dismisses the

complaint.

The Court holds a pro se complaint to a “less stringent standard[]” than is applied to a

pleading drafted by a lawyer. Haines v. Kerner, 404 U.S. 519, 520 (1972). Still, a pro se litigant

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). The Rule 8

standard ensures that defendants receive fair notice of 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). The Court dismisses the complaint for the simple reasons that there are no factual

allegations. Plaintiff submits the complaint on a preprinted form, and aside from identifying the

parties, asserting federal question jurisdiction, and signing the form, see Compl. at 1-3, 5, the form

is blank. Because the complaint falls well short of Rule 8’s minimal pleading standard, the Court

will dismiss it without prejudice. A separate order accompanies this Memorandum Opinion.

DATE: August 11, 2025 /s/ JIA M. COBB United States District Judge