Vang v. Social Security Administration
This text of Vang v. Social Security Administration (Vang v. Social Security Administration) 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.
Opinion
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
PAKUJA CRYSTAL VANG, ) ) Plaintiff, ) ) v. ) Civil Action No. 1:23-cv-02222 (UNA) ) SOCIAL SECURITY ) ADMINISTRATION, et al., ) ) ) Defendants. )
MEMORANDUM OPINION
Currently before the court is Plaintiff’s pro se complaint, ECF No. 1, and application for
leave to proceed in forma pauperis (“IFP”), ECF No. 2. For the reasons explained below, the court
will grant the Plaintiff’s IFP application, and will dismiss this matter without prejudice.
At the outset, the court notes that Plaintiff is currently unhoused, but domiciled in the
District of Columbia, and for that reason, she has moved, see ECF No. 4, to use a P.O. Box in lieu
of a residence address, see D.C. LCvR 5.1 (c)(1). The court finds good cause for use of a P.O.
Box in this circumstance and will thus grant Plaintiff’s motion. Plaintiff has also filed a motion to
seal, ECF No. 3, and although the relief sought is not entirely clear, it appears that she requests to
seal her P.O. Box address, as well as certain private information, stored on a USB drive, and sent
to the Clerk of Court. As far as it can be understood, the court finds good cause to seal Plaintiff’s
USB drive, also located at ECF No. 3, and to seal her address of record as requested, see D.C.
LCvR 5.1 (c)(1), therefore, that motion will also be granted, but to that extent only.
Notwithstanding the success of these motions, the complaint cannot survive.
1 Pro se litigants must comply with the 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
complaints to contain “(1) a short and plain statement of the grounds for the court’s jurisdiction
[and] (2) a short and plain statement of the claim showing that the pleader is entitled to relief.”
Fed. R. Civ. P. 8(a); see Ashcroft v. Iqbal, 556 U.S. 662, 678-79 (2009); Ciralsky v. CIA, 355 F.3d
661, 668-71 (D.C. Cir. 2004). The Rule 8 standard ensures that defendants receive fair notice of
the claim being asserted so that they can prepare a responsive answer and an adequate defense and
determine whether the doctrine of res judicata applies. Brown v. Califano, 75 F.R.D. 497, 498
(D.D.C. 1977). When a pleading “contains an untidy assortment of claims that are neither plainly
nor concisely stated, nor meaningfully distinguished from bold conclusions, sharp harangues and
personal comments [,]” it does not fulfill the requirements of Rule 8. Jiggetts v. D.C., 319 F.R.D.
408, 413 (D.D.C. 2017), aff’d sub nom. Cooper v. D.C., No. 17-7021, 2017 WL 5664737 (D.C.
Cir. Nov. 1, 2017). “A confused and rambling narrative of charges and conclusions . . . does not
comply with the requirements of Rule 8.” Cheeks v. Fort Myer Constr. Corp., 71 F. Supp. 3d 163,
169 (D.D.C. 2014) (citation and internal quotation marks omitted). The instant complaint falls
squarely within this category.
Plaintiff sues the Social Security Administration, the United States, and the State of
Maryland. The prolix complaint totals 96 pages, and includes a hodgepodge of unexplained
exhibits, see D.C. LCvR 5.1(e). The complaint is quite difficult to follow. Plaintiff cites to
approximately 20 different federal statutes and seven different constitutional amendments, broadly
alleging, without specificity, that Defendants and others, from September 2020 to date, have
committed medical malpractice, improperly denied her federal benefits and state benefits in
Maryland, discriminated against her on the basis of her disability, violated several of her
2 constitutional rights, abused her, conspired against her, committed various crimes, and engaged in
unfair settlement practices. Although Plaintiff invokes a litany of different laws, the expansive
nature of her intended claims does not help, and instead hampers, their comprehensibility, and
Plaintiff fails to make out a cognizable claim under any of the authority cited. She demands an
injunction correcting the laundry list of vague wrongdoing committed against her and she seeks
an unspecified award of damages. Put simply, the complaint is overbroad and fails to give
adequate notice of Plaintiff’s claims to the Defendants or to the court.
As a result, Plaintiff’s IFP application will be granted, and this matter will be dismissed
without prejudice for failure to satisfy Rule 8. A separate order accompanies this memorandum
opinion.
Date: October 23, 2023 ___________________________ JIA M. COBB United States District Judge
Free access — add to your briefcase to read the full text and ask questions with AI
Related
Cite This Page — Counsel Stack
Vang v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vang-v-social-security-administration-dcd-2023.