Willoughby v. United States America

CourtDistrict Court, District of Columbia
DecidedMay 13, 2025
DocketCivil Action No. 2025-1342
StatusPublished

This text of Willoughby v. United States America (Willoughby v. United States America) 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
Willoughby v. United States America, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ___________________________________ ) ZACHARY WILLOUGHBY, ) ) Plaintiff, ) ) v. ) Civil Action No. 25-1342 (UNA) ) UNITED STATES OF AMERICA, ) ) Defendant. ) ___________________________________ )

MEMORANDUM OPINION This matter is before the Court on consideration of Plaintiff’s application to proceed in

forma pauperis (ECF No. 2) and his pro se complaint (ECF No. 1). The Court grants the

application and, for the reasons discussed below, dismisses the complaint and this civil action.

According to Plaintiff, he has “not received Due Process in several court cases[.]”

Compl. (ECF No. 1) at 4. He alleges that an Associate Judge of the Superior Court of the

District of Columbia “refused to process” a case,” id., and that a District Court judge “den[ied

his] constitutional right to a trial” by “allow[ing the Defendant in that case] to not be served

summons,” id.1 After having “go[ne] over every crime committed,” Plaintiff asserts that

Defendant “will pay for each crime in full, to include[e] x2 for hate crime, x10 RICO, x1000

treason.” Id.

Plaintiff’s complaint borders on the indecipherable and, in any event, fails adequately to

allege jurisdiction or a cause of action. To start, only named Defendant is the United States, yet

1 Plaintiff identifies two civil actions. See Compl. at 4. Plaintiff filed a Praecipe voluntarily dismissing the Superior Court case. See Willoughby v. D.C. Gov’t, No. 2022-4306 (D.C. Super. Ct. Feb. 23, 2023). Judge Walton dismissed the district court case without prejudice for want of prosecution. See Willoughby v. District of Columbia, No. 23-cv-0594 (D.D.C. Jan. 17, 2024). 1 Plaintiff fails to identify an applicable waiver of sovereign immunity. In addition, he fails to

allege that the United States committed an identifiable legal wrong that caused him a

compensable injury. Moreover, even if the Court were to construe the complaint to assert claims

against the judges that Plaintiff identifies, he would be unable to recover. “Few doctrines were

more solidly established at common law than the immunity of judges from liability for damages

for acts committed within their judicial jurisdiction[.]” Pierson v. Ray, 386 U.S. 547, 553–54

(1967). Here, accepting Plaintiff’s allegations as true, the judges were acting in their judicial

capacities in managing the cases before them, even if Plaintiff objects to their rulings. Thus, the

judges are entitled to absolute judicial immunity from suit. See Mirales v. Waco, 502 U.S. 9, 11

(1991) (holding that “judicial immunity is an immunity from suit, not just from ultimate

assessment of damages”); Stump v. Sparkman, 435 U.S. 349, 364 (1978) (concluding that state

judge was “immune from damages liability even if his [decision] was in error”); Fuller v. Mott,

No. 14-cv-711, 2014 WL 1688038, at *1 (D.D.C. Apr. 23, 2014) (dismissing claim for damages

against Superior Court judge because he enjoys absolute immunity).

The Court will, accordingly, dismiss the complaint for failure adequate to allege subject-

matter jurisdiction and for failure to allege a claim upon which relief may be granted.

A separate order will issue.

DATE: May 9, 2025 /s/ RANDOLPH D. MOSS United States District Judge

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Related

Pierson v. Ray
386 U.S. 547 (Supreme Court, 1967)
Stump v. Sparkman
435 U.S. 349 (Supreme Court, 1978)
Mireles v. Waco
502 U.S. 9 (Supreme Court, 1991)

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Willoughby v. United States America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/willoughby-v-united-states-america-dcd-2025.