O'Diah v. United States Department of Justice

• Court: District Court, District of Columbia
• Decided: September 24, 2025
• Docket: Civil Action No. 2025-2220
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

AROR-ARK ARK O’DIAH,

Plaintiff,

v. Civil Action No. 25-cv-2220

UNITED STATES DEPARTMENT OF JUSTICE, et al.,

Defendants.

OPINION

Plaintiff Aror-Ark Ark O’Diah, proceeding pro se, alleges a far-reaching conspiracy

against over eighty Defendants, including the Chief Justice of the United States Supreme Court,

the Attorney General, the U.S. Attorney for the District of Columbia, several banking institutions

and businesses, the New York state government and its agencies, attorneys, and other civilians.

Compl. at 1–2, ECF No. 1 (“Compl.”). Plaintiff claims that Defendants acted in concert to defame

him, deny him access to credit lines and business loans, subject him to thirty-one false arrests, and

even to murder his late wife. Id. at 6–21. Eighteen motions to dismiss are pending, arguing, in

part, that the Complaint fails to state a claim for which relief can be granted. See ECF Nos. 7–8,

10, 16, 18, 22, 25, 27, 31, 38, 42, 47, 60, 73, 75, 77, 83–84. Because the court agrees, it will

GRANT those motions, sua sponte DISMISS the Complaint against all other Defendants, and

DENY AS MOOT all remaining motions.

A district court “may sua sponte dismiss a claim pursuant to Rule 12(b)(6) without notice

where it is ‘patently obvious’ that the plaintiff cannot possibly prevail based on the facts alleged

in the complaint.” Jafari v. United States, 83 F. Supp. 3d 277, 279 (D.D.C. 2015) (quoting Rollins

Page 1 of 3 v. Wackenhut Servs., Inc., 703 F.3d 122, 127 (D.C. Cir. 2012)), aff’d, 621 F. App’x 676 (D.C. Cir.

2015); see also Tate v. Burke, 131 F.R.D. 363, 365 (D.D.C. 1990) (courts may act sua sponte when

the complaint “indisputedly” contains “no factual and legal basis for the asserted wrong”). While

the court recognizes that complaints 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), even pro se litigants must comply with the Federal Rules of Civil Procedure, Jarrell

v. Tisch, 656 F. Supp. 237, 239 (D.D.C. 1987).

Plaintiff appears to re-allege many of the same claims that another court in this district

recently dismissed. In that case, Plaintiff also alleged a “sweeping conspiracy to murder him and

conceal white-collar crimes” and brought claims of “wrongful death, false imprisonment, and other

alleged harms.” Order at 1, O’Diah v. Moss, No. 24-cv-2736 (D.D.C. June 2, 2025) (“Order”);

see also Lewis v. Drug Enforcement Admin., 777 F. Supp. 2d 151, 159 (D.D.C. 2011) (“The court

may take judicial notice of public records from other court proceedings.”). The only significant

differences in this case are that here, Plaintiff added nearly sixty new defendants to the twenty-

three he sued before. Compare Compl. at 1, with Order at 1. He also increased his damages to $1

billion per defendant, instead of $100 million per defendant. Compare Compl. at 22, with Order

at 1. Enlarging the scope of the lawsuit cannot save this case from a similar fate. Because the

Complaint “veers between indecipherable claims and conclusory legal assertions,” “fail[ing] to

explain how specific actions by specific Defendants violated the law,” dismissal is also warranted

here. Order at 2.

The Eastern District of New York already limited Plaintiff’s ability to file future lawsuits

based on many of the same allegations he makes here. See O’Diah v. City of New York, No. 8-cv-

1646, 2008 WL 1968303, at *1 (E.D.N.Y. Apr. 30, 2008) (“Accordingly, plaintiff is hereby

Page 2 of 3 enjoined from filing future lawsuits in the United States District Court for the Eastern District of

New York without first obtaining leave of the Court and from filing any lawsuit in any other court

based upon the same facts and issues dating from November 6, 2002 to November 13, 2007.”).

This court will not hesitate to issue a similar order if Plaintiff continues to repackage previously

dismissed claims into new cases. Kennedy v. Boardman, 233 F. Supp. 3d 117, 122 (D.D.C. 2017)

(dismissing a complaint with prejudice “to protect against the expense and vexation attending

multiple lawsuits [and] conserve judicial resources”). Each time Plaintiff does so, he forces

Defendants to “expend unnecessary resources to defend themselves.” DirecTV Mot. to Dismiss

at 1, ECF No. 47-1.

Accordingly, it is “patently obvious” that Plaintiff cannot prevail based on the facts alleged

in his Complaint. Rollins, 703 F.3d at 127. Each pending motion to dismiss, ECF Nos. 7–8, 10,

16, 18, 22, 25, 27, 31, 38, 42, 47, 60, 73, 75, 77, 83–84, is GRANTED, and the Complaint is sua

sponte DISMISSED WITHOUT PREJUDICE against every remaining Defendant. The

Unopposed Motion for Scheduling Order, ECF No. 81, and the Motion for Injunction, ECF No.

89, are DENIED AS MOOT. A corresponding order shall follow.

Date: September 24, 2025

Tanya S. Chutkan TANYA S. CHUTKAN United States District Judge

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