West v. Bost

• Court: District Court, District of Columbia
• Decided: November 5, 2025
• Docket: Civil Action No. 2025-2589
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

LEO WEST,

Plaintiff,

v. Civil Action No. 1:25-cv-02589 (UNA)

MIKE BOST, et al.,

Defendant.

MEMORANDUM OPINION

Before the Court is Plaintiff Leo West’s pro se Complaint, ECF No. 1, and Application for

Leave to Proceed in forma pauperis (“IFP”), ECF No. 2. The Court grants Plaintiff’s IFP

Application and, for the reasons explained below, dismisses this matter without prejudice.

West, a resident of the District of Columbia, sues several members of Congress, whom he

refers to as “Governors.” See Compl. at 1–6. The allegations are sparse and vague. Plaintiff

alleges that Defendants violated 18 U.S.C. § 1001 by making contradictory and “fraudulent

statements” regarding a “government shelter.” See id. at 7, 9. The remainder of the Complaint

consists of mere phrases, presented without context in sentence fragments or less, for example,

“access housing/veteran affairs,” “false application on government shelter,” “confusing voices,”

and “false actuzation” [sic]. See id. He demands $14 million in damages. See id. at 7.

First, pro se litigants must comply with the Federal Rules of Civil Procedure, Jarrell v.

Tisch, 656 F. Supp. 237, 239 (D.D.C. 1987), and Rule 8 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, 677–79 (2009). The Rule 8 standard ensures that defendants receive fair

1 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). Here, as presented, neither the Court nor the Defendants can reasonably

be expected to identify Plaintiff’s intended claims, and the allegations fall well short of stating a

plausible claim or establishing the Court’s subject matter jurisdiction. Second, Plaintiff’s reliance

on 18 U.S.C. § 1001, a criminal statute, is misplaced because that statute does not provide a private

right of action. See Lee v. U.S. Agency for Int’l Dev., 859 F.3d 74, 78 (D.C. Cir. 2017) (per curiam).

For all these reasons, this case is dismissed without prejudice. A separate Order

accompanies this Memorandum Opinion.

DATE: November 5, 2025 CARL J. NICHOLS United States District Judge