Watkins v. Heastie-Graham

• Court: District Court, District of Columbia
• Decided: March 19, 2026
• Docket: Civil Action No. 2026-0301
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

RONALD K. WATKINS,

Plaintiff,

v. Case No. 1:26-cv-301 (TNM)

VEDELL NEE HEASTIE-GRAHAM,

Defendant.

MEMORANDUM OPINION

Pro se plaintiff Ronald Watkins sues over a car accident that occurred in November 2025.

Compl. ¶ 5, ECF No.1. In his telling, Vedell Nee Heastie-Graham negligently made an illegal

turn and crashed into Watkins’ car. Id. ¶ 6. The crash allegedly caused Watkins several physical

and emotional injuries. Id. So he turned to this Court. Watkins sues Heastie-Graham for

$550,000 in damages. Id. ¶ 9. But Watkins has not met his obligation to establish this Court’s

jurisdiction. The Court will accordingly dismiss his Complaint without prejudice.

“If the [district] court determines at any time that it lacks subject-matter jurisdiction, the

court must dismiss the action.” Fed. R. Civ. P. 12(h)(3). A party seeking relief from this Court

must plead facts that bring the suit within the court’s jurisdiction. See Fed. R. Civ. P. 8(a).

Should it not, this Court may dismiss his complaint “sua sponte prior to service on the

defendants” if “it is evident that the court lacks subject matter-jurisdiction.” Evans v. Suter, No.

09–5242, 2010 WL 1632902, at *1 (D.C. Cir. Apr. 2, 2010); see also Hurt v. U.S. Court of

Appeals for the D.C. Cir., 264 F.App’x. 1, 1 (D.C. Cir. 2008); Scholastic Ent., Inc. v. Fox Ent.

Grp., Inc., 336 F.3d 982, 985 (9th Cir. 2003) (“While a party is entitled to notice and an opportunity to respond when a court contemplates dismissing a claim on the merits . . . it is not

so when the dismissal is for lack of subject matter jurisdiction.”).

That said, the Court must construe a pro se complaint liberally, keeping in mind that

complaints filed by pro se litigants are held to a less stringent standard than formal pleadings

drafted by lawyers. Erickson v. Pardus, 551 U.S. 89, 94 (2007). But even pro se litigants must

meet the minimum pleading standards required by the Federal Rules and the Constitution. See

Yellen v. U.S. Bank, Nat’l Ass’n, 301 F. Supp. 3d 43, 47 (D.D.C. 2018). That includes rules for

alleging subject matter jurisdiction. Stoller v. United States, 216 F. Supp. 3d 171, 174 (D.D.C.

2016); see also Atherton v. D.C. Off. of Mayor, 567 F.3d 672, 681–82 (D.C. Cir. 2009).

Watkin’s Complaint falls short of these requirements. In a section of his Complaint

establishing the “[b]asis for [j]urisdiction” as “[d]iversity,” he states that he is a “citizen” of

Maryland, and he states that Heastie-Graham is also a “citizen” of Maryland. Compl. at 3.

Later, he again alleges that he “is a resident of the State of Maryland” and that Defendant “is a

resident of the State” of “Maryland.” Id. ¶ 1–2. These allegations pose a problem for Watkins

because diversity jurisdiction requires the parties be “citizens of different States.” 28 U.S.C.

§ 1332(a).

And while the car accident prompting his lawsuit occurred in Washington, D.C., that

plays no role in diversity jurisdiction, which focuses only on the parties’ domicile. Prakash v.

Am. Univ., 727 F.2d 1174, 1180 (D.C. Cir. 1984). Diversity jurisdiction thus lacks. See 28

U.S.C. § 1332(a).

Watkins provides no hook for federal question jurisdiction either. His Complaint sounds

in state tort law claims. He claims Heastie-Graham drove into his car and faults him for

“negligence and carelessness” that injured Watkins. Compl. ¶¶ 5–6, 8. He points to the

2 “medical costs and expenses” he will incur as a result. Id. ¶ 8. And while he lists a smattering of

federal laws at the top of his Complaint, see id. at 3 (listing the Federal Arbitration Act, the Fifth

Amendment, the Fourteenth Amendment, 28 U.S.C. § 1738, and 28 U.S.C. § 2202), he provides

no “short and plain statement” making out any those claims. Fed. R. Civ. P. 8(a); see Ashcroft v.

Iqbal, 556 U.S. 662, 678–79 (2009). From the face of his Complaint, one gleans only his

negligence claim. Nothing in it leaves the Defendant able to prepare a responsive answer or

mount an adequate defense to any federal law claim—let alone several—if Watkins is in fact

pursuing those claims instead of his negligence claim. See Brown v. Califano, 75 F.R.D. 497,

498 (D.D.C. 1977) (explaining that the purpose of Rule 8 is to give defendants fair notice of a

plaintiff’s claims so they made properly respond). Watkins thus has not presented a federal

question suitable for this Court’s decision.

Put simply, Watkins fails to establish this Court’s jurisdiction. The Court accordingly

will dismiss his Complaint without prejudice. A separate order accompanies this opinion.

2026.03.19 09:47:32 -04'00' Dated: March 19, 2026 TREVOR N. McFADDEN United States District Judge