Priest v. Priest

• Court: District Court, District of Columbia
• Decided: January 21, 2026
• Docket: Civil Action No. 2026-0096
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA _________________________________________ ) STEVEN PAUL PRIEST, ) ) Plaintiff, ) ) v. ) Case No. 26-cv-00096 (APM) ) STEVEN PAUL PRIEST, ) ) Defendant. ) _________________________________________ )

MEMORANDUM OPINION

Pro se Plaintiff Steven Paul Priest, self-designated as “holder In Due Course” and “Foreign

Sovereign,” brings claims against apparently himself as a “non-juridic, Assumption, is Trust Res,

‘Public Office.’” Compl., ECF No. 1 [hereinafter Compl.], at 1. Because Plaintiff fails to raise a

substantial federal question and his claims are patently frivolous, the court sua sponte dismisses

the Complaint and this action.

It is well settled that “federal courts are without power to entertain claims otherwise within

their jurisdiction if they are so attenuated and unsubstantial as to be absolutely devoid of merit” or

“obviously frivolous.” Hagans v. Lavine, 415 U.S. 528, 536–37 (1974) (internal quotation marks

and citations omitted). A complaint will be dismissed pursuant to Federal Rule of Civil Procedure

12(b)(1) when it is “‘patently insubstantial,’ presenting no federal question suitable for decision.”

Best v. Kelly, 39 F.3d 328, 330 (D.C. Cir. 1994) (quoting Neitzke v. Williams, 490 U.S. 319, 327

n.6 (1989)). Claims are insubstantial and frivolous if they are “essentially fictitious” because they

advance, for example, “bizarre conspiracy theories.” Best, 39 F.3d at 330 (internal quotation marks

omitted). In such cases, a district court may dismiss the case sua sponte. See Lewis v. Bayh, 577 F. Supp. 2d 47, 54 (D.D.C. 2008) (noting that “a district court has the power to dismiss a case sua

sponte if it is frivolous”).

It is neither clear what claims Plaintiff brings nor what relief he seeks. The Complaint

alludes to “[c]ompelled association of public office outside the District of Columbia” and that

Plaintiff is “taking back [his] property, and then promptly, intend[s] to exit the Federal Enclave.”

Compl. at 2. Plaintiff fails to explain what “[c]ompelled association of public office” is or what

that has to do with property. Id. Plaintiff appears to request “To Enjoin, STATE actors, from TM

Infringement, violating public to use a similar named tradename, without consent, under duress,

by misrepresentation & fraud upon purchasing public, as to qualify of my property, that differs

from anyone else but me!” Id. (emphasis in original). Again, Plaintiff does not explain what “TM

Infringement” is nor does he explain the rest of the sentence, which does not express a discernable

request for relief. The Complaint does not present a federal question suitable for relief and thus

must be dismissed for failure to state a claim.

The court is mindful 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). But Plaintiff’s claims are “patently insubstantial” and present “no

federal question suitable for decision.” Best, 39 F.3d at 330 (citations omitted). Accordingly, the

court dismisses the Complaint and this action for lack of subject matter jurisdiction.

A separate final, appealable order accompanies this Memorandum Opinion.

Dated: January 21, 2026 Amit P. Mehta United States District Judge