Petrozzi v. Bowser

• Court: District Court, District of Columbia
• Decided: September 2, 2025
• Docket: Civil Action No. 2025-2372
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

TIMOTHY R. PETROZZI, ) ) Plaintiff, ) ) v. ) Civil Action No. 25-2372 (UNA) ) MURIEL BOWSER, 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 in forma pauperis 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). 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

1 whether the doctrine of res judicata applies. See Brown v. Califano, 75 F.R.D. 497, 498 (D.D.C.

1977).

Plaintiff alleges that his “cellular device . . . was ‘Phished, Hacked and Compromised,’”

Compl. at 3, by the Federal Bureau of Investigation, id. This appears to be the complaint’s sole

understandable allegation. Otherwise, notwithstanding its length, the complaint fails to meet the

minimal pleading standard set forth in Rule 8(a). It simply does not contain a short and plain

statement showing Plaintiff’s entitlement to relief, and the exhibits he attaches to the complaint

shed no light on the nature or substance of an actual legal claim. There are far too few cogent

factual allegations, and no defendant has proper notice of the claim(s) plaintiff is bringing.

An Order is issued separately.

DATE: September 2, 2025 /s/ JIA M. COBB United States District Judge