Thornton v. Biden

• Court: District Court, District of Columbia
• Decided: January 22, 2026
• Docket: Civil Action No. 2025-0178
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JAMEL VICTOR THORNTON,

Plaintiff, Civil Action No. 25-00178 (AHA) v.

JOSEPH R. BIDEN, JR.,

Defendant.

Memorandum Opinion

Jamel Thornton sues former President Joseph R. Biden, alleging President Biden failed to

disclose information about his health and that health issues compromised his ability to perform his

duties as President. Thornton claims this conduct violates multiple constitutional provisions, and

he seeks a “judicial determination of the President’s fitness for office, an order requiring the

disclosure of relevant medical and cognitive evaluations necessary to assess the President’s

capacity to execute his constitutional responsibilities, and a writ of mandamus directing” certain

executive branch officials “to fulfill their constitutional obligations under the Twenty-Fifth

Amendment.” ECF No. 1 ¶ 10. President Biden moves to dismiss, arguing, among other things,

that Thornton does not have standing. The court agrees and grants the motion.

When considering a motion to dismiss for lack of subject matter jurisdiction, 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. F.D.I.C., 642 F.3d 1137, 1139 (D.C. Cir. 2011) (quoting Thomas v. Principi,

394 F.3d 970, 972 (D.C. Cir. 2005)). Because Thornton is proceeding pro se, the court is careful

to give extra leeway, evaluating the complaint “in light of all filings.” Ho v. Garland, 106 F.4th 47, 50 (D.C. Cir. 2024) (quotation marks omitted) (quoting Brown v. Whole Foods Mkt. Grp., Inc.,

789 F.3d 146, 152 (D.C. Cir. 2015)). To have standing, a plaintiff must plausibly allege they have

“suffered, or will suffer, an injury that is ‘concrete, particularized, and actual or imminent; fairly

traceable to the challenged action; and redressable by a favorable ruling.’” Murthy v. Missouri,

603 U.S. 43, 57 (2024) (quoting Clapper v. Amnesty Int’l USA, 568 U.S. 398, 409 (2013)). If a

plaintiff fails to establish standing, the court “lack[s] jurisdiction to reach the merits.” Id. at 56.

Thornton does not have standing because he does not allege concrete and particularized

injury. The complaint alleges President Biden’s “refusal to release critical health information

undermines public trust, creates uncertainty about his capacity to govern, and poses systemic risks

to state sovereignty, individual rights, and national stability.” ECF No. 1 ¶ 5. The complaint also

alleges various actions and policy decisions by President Biden that Thornton believes evince

cognitive and physical impairments and a lack of forthrightness about such alleged impairments.

Id. ¶¶ 23–61. But Thornton fails to allege any particular harm to him. Rather, he alleges “precisely

the kind of undifferentiated, generalized grievance[s] about the conduct of government that

[courts] have refused to countenance in the past.” Lance v. Coffman, 549 U.S. 437, 442 (2007).

Because Thornton has not adequately alleged injury, he does not have standing.

Accordingly, President Biden’s motion to dismiss is granted, and this action is dismissed

without prejudice.

A separate order accompanies this memorandum opinion.

AMIR H. ALI United States District Judge

Date: January 22, 2026