Smith v. Flores

CourtDistrict Court, District of Columbia
DecidedJanuary 22, 2026
DocketCivil Action No. 2025-1042
StatusPublished

This text of Smith v. Flores (Smith v. Flores) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smith v. Flores, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

K.L. SMITH,

Plaintiff,

v. Civil Action No. 25-cv-1042 (CJN)

PETE R. FLORES, et al.,

Defendants.

MEMORANDUM OPINION

Plaintiff K.L Smith, proceeding pro se, sued President Donald J. Trump, Vice President

J.D. Vance, former acting commissioner of U.S. Customs and Border Protection Pete R. Flores,

several Supreme Court Justices, Elon Musk, Congressman James Michael Johnson, and 500

unnamed Defendants, alleging various political grievances and conspiracy theories. See ECF No.

20 (“Compl.”). The government moves to dismiss. See ECF No. 42. For the reasons discussed

below, the Court grants that motion and dismisses this case.

I. Background

To the extent it can be understood, Smith’s nine-count complaint claims that President

Trump lacks “legal authority to serve as President of the United States;” suppresses Smith’s access

to truthful reporting”; serves “foreign and domestic benefactors in exchange for personal and

financial gain;” fails to enforce the law; “suppresses eligible voters” by requiring proof of

citizenship to vote; and is “unconstitutional[ly] enrich[ed]” by unlawfully holding office. Compl.

at ¶¶ 202, 207–08, 215–19, 228, 262, 264. Smith further asserts that he “has suffered and will

continue to suffer injury from the Conspiring [Supreme Court] Justices’ systematic corruption of

the judiciary,” and that he “faces imminent harm from DOGE’s” cuts to his social security benefits.

1 Id. at ¶¶ 225, 245. Although Smith’s complaint is rambling and often unintelligible, his core

contention seems to be that President Trump cannot lawfully be President and everything he has

done in office is “void as a matter of law.” Id. ¶ 202; see generally id. For relief, Smith seeks a

declaration that President Trump cannot serve as President, an injunction forbidding Flores from

collecting tariffs imposed by President Trump’s “void Executive Orders,” an injunction forbidding

Justices “Roberts, Thomas, Alito, Gorsuch, Kavanaugh, and Barrett from wielding judicial

power,” and compensatory and punitive damages for his losses, among other things. See id. at 56–

57.1

II. Legal Standard

To survive a motion to dismiss under Rule 12(b)(1), a plaintiff—even one proceeding pro

se—bears the burden of establishing that the Court has subject-matter jurisdiction over his claims.

See Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992); Strunk v. Obama, 880 F. Supp. 2d 1, 3

(D.D.C. 2011) (“[T]he requirement that courts liberally interpret pro se pleadings does not

dispense with the constitutional requirement of standing.”).2 In deciding a 12(b)(1) motion, the

Court “need not limit itself to the allegations of the complaint.” Grand Lodge of the Fraternal

Ord. of Police v. Ashcroft, 185 F. Supp. 2d 9, 14 (D.D.C. 2001). Rather, the Court “may consider

materials outside the pleadings in deciding whether to grant a motion to dismiss for lack of

1 The Court cites to the complaint’s page numbers here, because Smith stopped using numbered paragraphs at the end of his complaint. 2 The government also moves to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing that Smith’s complaint fails to state a claim upon which relief can be granted. See ECF No. 42 at 6–7. Because the Court concludes that it lacks jurisdiction over Smith’s claims, it need not decide whether Smith’s complaint satisfies Rule 12(b)(6). See Newby v. Obama, 681 F. Supp. 2d 53, 55 n. 6 (D.D.C. 2010) (“Because the Court concludes that it does not have subject matter jurisdiction over plaintiff's claims, it need not reach the question of whether plaintiff adequately stated a claim under Rule 12(b)(6) or whether the doctrines of collateral estoppel and res judicata apply.”); Curran v. Holder, 626 F. Supp. 2d 30, 32 (D.D.C. 2009).

2 jurisdiction.” Jerome Stevens Pharm., Inc. v. FDA, 402 F.3d 1249, 1253 (D.C. Cir. 2005).

Additionally, the Court must “assume the truth of all material factual allegations in the complaint

and construe the complaint liberally, granting plaintiff the benefit of all inferences that can be

derived from the facts alleged.” Am. Nat. Ins. Co. v. FDIC, 642 F.3d 1137, 1139 (D.C. Cir. 2011)

(internal quotation marks omitted). The factual allegations in a plaintiff’s complaint, however,

“‘will bear closer scrutiny in resolving a 12(b)(1) motion’ than in resolving a 12(b)(6) motion for

failure to state a claim.” Grand Lodge, 185 F. Supp. 2d at 13–14 (quoting 5A Charles A. Wright

& Arthur R. Miller, Fed. Practice & Procedure § 1350 (2d ed. 1987)). If the Court finds that it

lacks jurisdiction over a claim, it must dismiss that claim without prejudice. Fed. R. Civ. P.

12(b)(1), 12(h)(3); see N. Am. Butterfly Ass’n v. Wolf, 977 F.3d 1244, 1253 (D.C. Cir. 2020).

III. Analysis

Article III of the Constitution limits federal courts’ jurisdiction to resolving “cases” or

“controversies.” U.S. Const. art. III, § 2, cl. 1. “A showing of standing is [therefore] an essential

and unchanging predicate to any exercise of [federal court] jurisdiction.” Grand Lodge, 185 F.

Supp. 2d at 14 (alterations in original) (internal quotation marks omitted) (quoting Florida

Audubon Soc. v. Bentsen, 94 F.3d 658, 663 (D.C. Cir. 1996)). “[T]o establish standing, a plaintiff

must show (i) that he suffered an injury in fact that is concrete, particularized, and actual or

imminent; (ii) that the injury was likely caused by the defendant; and (iii) that the injury would

likely be redressed by judicial relief.” TransUnion LLC v. Ramirez, 594 U.S. 413, 423 (2021)

(citing Lujan, 504 U.S. at 560–61). “For an injury to be particularized, it must affect the plaintiff

in a personal and individual way,” and for it to be concrete, it must be “real, and not abstract.”

Spokeo, Inc. v. Robins, 578 U.S. 330, 339–40 (2016) (internal quotation marks omitted).

3 Here, Smith has failed plausibly to allege Article III standing. His complaint sets forth an

array of political grievances and conspiracy theories about various federal officials and public

figures but contains no factual allegations explaining how he has been personally or concretely

injured by the events or actions he describes. Cf. Strunk, 880 F. Supp. 2d 1

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Related

Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Lance v. Coffman
549 U.S. 437 (Supreme Court, 2007)
American Nat. Ins. Co. v. FDIC
642 F.3d 1137 (D.C. Circuit, 2011)
Panko v. Rodak
606 F.2d 168 (Seventh Circuit, 1979)
Hollingsworth v. Perry
133 S. Ct. 2652 (Supreme Court, 2013)
Curran v. Holder
626 F. Supp. 2d 30 (District of Columbia, 2009)
Newby v. Obama
681 F. Supp. 2d 53 (District of Columbia, 2010)
Grand Lodge of the Fraternal Order of Police v. Ashcroft
185 F. Supp. 2d 9 (District of Columbia, 2001)
Spokeo, Inc. v. Robins
578 U.S. 330 (Supreme Court, 2016)
TransUnion LLC v. Ramirez
594 U.S. 413 (Supreme Court, 2021)
Strunk v. Obama
880 F. Supp. 2d 1 (District of Columbia, 2011)
Linda R. S. v. Richard D.
410 U.S. 614 (Supreme Court, 1973)

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Smith v. Flores, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-flores-dcd-2026.