UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
SAM WISE,
Plaintiff,
Civil Action No. 25-1271 (RDM) v.
UNITED STATES DEPARTMENT OF JUSTICE, et al.,
Defendants.
MEMORANDUM OPINION
Plaintiff, proceeding pro se, brings this action against the United States Department of
Justice (“DOJ”), the Federal Bureau of Investigation, the United States Department of Health
and Human Services, the Washington State Department of Health, the Texas Board of Dental
Examiners, Dr. Umair Shah, Dr. Meryam Nossa, Austin Covington, Mark Crandall, the
Honorable Lindsey R. Cotterell, the Honorable Gary Bashor, the Honorable “Judge Evans,” and
the Washington Court of Appeals, Division II. Dkt. 1. at 1 (Compl.). Plaintiff alleges that he is
a “federally protected whistleblower” who brings suit to “expose and [to] seek redress for a
wide-ranging, multi-agency campaign of retaliation and suppression.” Id. (Compl.). According
to Plaintiff, the case presents an “airtight and evidence-loaded account of FBI misconduct, DOJ
cover-up, state retaliation, judicial sabotage, and witness perjury—all coordinated to punish
lawful disclosures of public corruption and institutional fraud.” Id.
Plaintiff asserts claims for First Amendment retaliation; violations of the Fifth and
Fourteenth Amendments’ due process guarantees and the equal protection clause; civil
conspiracy pursuant to 42 U.S.C. § 1985; malicious prosecution; abuse of process; negligent supervision and oversight; deprivation of rights under color of state law pursuant to 42 U.S.C.
§ 1983; abuse of process and retaliatory inspection by Defendant Mark Crandall; and civil
conspiracy and forgery by Defendant Austin Covington. Id. at 5 (Compl.). He seeks $24 million
in damages, a reinstatement of his suspended licenses “with public apology,” and various other
forms of injunctive relief. Id.
I. BACKGROUND
Plaintiff alleges that he is a “triple-board-certified oral surgeon,” who faced, in one year,
fifty-one “board complaints,” which resulted in the suspension of his license and the imposition
of a $45,000 fine. Id. at 2–3 (Compl.). In March of 2025, Plaintiff “filed a federal whistleblower
complaint” based on the suspension of his license, and, three days later, the Texas Dental Board
“reactivated a long-dormant anonymous complaint” that alleged misconduct in Plaintiff’s
placement of a temporary crown. Id. at 3 (Compl.). This allegation, which Plaintiff asserts was
frivolous, resulted in a “five-year suspension” of his Texas license. Id. (Compl.).
Plaintiff appears to connect the suspension of his license to a Dr. Daniel Haghighi, who
he alleges (although, Plaintiff has not named Dr. Haghighi as a defendant in the case) has
“maintained active ties with Iranian intelligence, given [Dr. Haghighi’s] outsized influence over
multiple institutions and actors across two states.” Id. at 2 (Compl.). Plaintiff claims that Dr.
Haghighi’s “political reach” extended “inexplicably” to include “judicial officers . . . state
officials” on the dental boards, and “federal agents within the FBI.” Id. (Compl.). Dr.
Haghighi’s reach can only be explained, according to Plaintiff, by “the involvement of
international intelligence affiliations.” Id. (Compl.). Although it is unclear if the suspension is
connected, Plaintiff also alleges that one of his former attorneys conspired with Dr. Haghighi,
2 Defendant Covington, and an unnamed judge, in a proceeding before a biased arbitrator. Id. at 4
(Compl.).
According to Plaintiff, at some point in 2020, the “FBI raided” his clinics in Washington
and Texas over a “$90 billing discrepancy.” Id. (Compl.). DOJ allegedly conducted a parallel
investigation with the FBI involving the billing discrepancy. Id. (Compl.). The FBI and DOJ
“refused to confirm closure of the case,” which left Plaintiff “under permanent threat.” Id.
(Compl.). Plaintiff then alleges that in 2022, Judge Lindsey Cotterell “issued a one-week
eviction despite lease grace provisions, forcing sudden closure of an active clinic treating
surgical cases.” Id. (Compl.). Finally, Plaintiff gestures towards separate cases, without
providing any description of the factual circumstances surrounding these cases, as evidence of
“judicial bias.” Id. (Compl.). He alleges that “all of [his] witnesses were excluded” and that the
plaintiff in one of those cases, Darci Cooper, was “awarded $800,000 in emotional distress”
damages, which Plaintiff claims is an “unprecedented judgment.” Id. (Compl.).
II. ANALYSIS
Although courts hold pro se pleadings “to less stringent standards than formal pleadings
drafted by lawyers,” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (internal quotation marks and
citation omitted), the Court may dismiss a complaint sua sponte under Federal Rules of Civil
Procedure 8(a) and 12(b)(6) if “it is patently obvious” that the plaintiff cannot “prevail[] on the
facts alleged in his complaint,” Baker v. Director, U.S. Parole Comm'n, 916 F.2d 725, 727 (D.C.
Cir. 1990); see also Strunk v. Obama, 880 F. Supp. 2d 1, 3 (D.D.C. 2011), or under Rule
12(b)(1) if the complaint fails to allege facts sufficient to invoke the Court’s subject-matter
jurisdiction. This is such a case.
3 Most fundamentally, the complaint fails to comply with Rule 8(a) of the Federal Rules of
Civil Procedure, which requires “a short and plain statement of the claim showing that the
pleader is entitled to relief.” Fed. R. Civ. P. 8(a). This requirement “ensures that the opposing
party will receive ‘fair notice of what the . . . claim is and the grounds upon which it rests.’”
Jones v. Changsila, 271 F. Supp. 3d 9, 21 (D.D.C. 2017) (quoting Erickson v. Pardus, 551 U.S.
89, 93 (2007)). “Where a complaint is insufficiently focused, it places an undue burden on the
defendant to answer or move[,] and it invites unnecessary delay and confusion in the
proceedings.” Achagzai v. Broad. Bd. of Governors, 109 F. Supp. 3d 67, 71 (D.D.C. 2015).
Here, Plaintiff’s complaint contains a series of vague factual assertions and legal
conclusions. He alleges, for example, that the judicial Defendants engaged in a “pattern of
coordinated bias [that] severely compromised the integrity” of various proceedings. Dkt. 1 at 4
(Compl.). Even when considered liberally, the complaint offers no meaningful indication of
what happened or of why the alleged events, if accepted as true, would entitle Plaintiff to relief.
See Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 563 (2007). It includes, for example, vague
references to “Iranian intelligence,” Dkt. 1 at 2 (Compl.), to improper “political reach” and
“personal manipulation,” id. at 3 (Compl.), and to the Texas Dental Board’s “incompetence and
political bias,” id.
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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
SAM WISE,
Plaintiff,
Civil Action No. 25-1271 (RDM) v.
UNITED STATES DEPARTMENT OF JUSTICE, et al.,
Defendants.
MEMORANDUM OPINION
Plaintiff, proceeding pro se, brings this action against the United States Department of
Justice (“DOJ”), the Federal Bureau of Investigation, the United States Department of Health
and Human Services, the Washington State Department of Health, the Texas Board of Dental
Examiners, Dr. Umair Shah, Dr. Meryam Nossa, Austin Covington, Mark Crandall, the
Honorable Lindsey R. Cotterell, the Honorable Gary Bashor, the Honorable “Judge Evans,” and
the Washington Court of Appeals, Division II. Dkt. 1. at 1 (Compl.). Plaintiff alleges that he is
a “federally protected whistleblower” who brings suit to “expose and [to] seek redress for a
wide-ranging, multi-agency campaign of retaliation and suppression.” Id. (Compl.). According
to Plaintiff, the case presents an “airtight and evidence-loaded account of FBI misconduct, DOJ
cover-up, state retaliation, judicial sabotage, and witness perjury—all coordinated to punish
lawful disclosures of public corruption and institutional fraud.” Id.
Plaintiff asserts claims for First Amendment retaliation; violations of the Fifth and
Fourteenth Amendments’ due process guarantees and the equal protection clause; civil
conspiracy pursuant to 42 U.S.C. § 1985; malicious prosecution; abuse of process; negligent supervision and oversight; deprivation of rights under color of state law pursuant to 42 U.S.C.
§ 1983; abuse of process and retaliatory inspection by Defendant Mark Crandall; and civil
conspiracy and forgery by Defendant Austin Covington. Id. at 5 (Compl.). He seeks $24 million
in damages, a reinstatement of his suspended licenses “with public apology,” and various other
forms of injunctive relief. Id.
I. BACKGROUND
Plaintiff alleges that he is a “triple-board-certified oral surgeon,” who faced, in one year,
fifty-one “board complaints,” which resulted in the suspension of his license and the imposition
of a $45,000 fine. Id. at 2–3 (Compl.). In March of 2025, Plaintiff “filed a federal whistleblower
complaint” based on the suspension of his license, and, three days later, the Texas Dental Board
“reactivated a long-dormant anonymous complaint” that alleged misconduct in Plaintiff’s
placement of a temporary crown. Id. at 3 (Compl.). This allegation, which Plaintiff asserts was
frivolous, resulted in a “five-year suspension” of his Texas license. Id. (Compl.).
Plaintiff appears to connect the suspension of his license to a Dr. Daniel Haghighi, who
he alleges (although, Plaintiff has not named Dr. Haghighi as a defendant in the case) has
“maintained active ties with Iranian intelligence, given [Dr. Haghighi’s] outsized influence over
multiple institutions and actors across two states.” Id. at 2 (Compl.). Plaintiff claims that Dr.
Haghighi’s “political reach” extended “inexplicably” to include “judicial officers . . . state
officials” on the dental boards, and “federal agents within the FBI.” Id. (Compl.). Dr.
Haghighi’s reach can only be explained, according to Plaintiff, by “the involvement of
international intelligence affiliations.” Id. (Compl.). Although it is unclear if the suspension is
connected, Plaintiff also alleges that one of his former attorneys conspired with Dr. Haghighi,
2 Defendant Covington, and an unnamed judge, in a proceeding before a biased arbitrator. Id. at 4
(Compl.).
According to Plaintiff, at some point in 2020, the “FBI raided” his clinics in Washington
and Texas over a “$90 billing discrepancy.” Id. (Compl.). DOJ allegedly conducted a parallel
investigation with the FBI involving the billing discrepancy. Id. (Compl.). The FBI and DOJ
“refused to confirm closure of the case,” which left Plaintiff “under permanent threat.” Id.
(Compl.). Plaintiff then alleges that in 2022, Judge Lindsey Cotterell “issued a one-week
eviction despite lease grace provisions, forcing sudden closure of an active clinic treating
surgical cases.” Id. (Compl.). Finally, Plaintiff gestures towards separate cases, without
providing any description of the factual circumstances surrounding these cases, as evidence of
“judicial bias.” Id. (Compl.). He alleges that “all of [his] witnesses were excluded” and that the
plaintiff in one of those cases, Darci Cooper, was “awarded $800,000 in emotional distress”
damages, which Plaintiff claims is an “unprecedented judgment.” Id. (Compl.).
II. ANALYSIS
Although courts hold pro se pleadings “to less stringent standards than formal pleadings
drafted by lawyers,” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (internal quotation marks and
citation omitted), the Court may dismiss a complaint sua sponte under Federal Rules of Civil
Procedure 8(a) and 12(b)(6) if “it is patently obvious” that the plaintiff cannot “prevail[] on the
facts alleged in his complaint,” Baker v. Director, U.S. Parole Comm'n, 916 F.2d 725, 727 (D.C.
Cir. 1990); see also Strunk v. Obama, 880 F. Supp. 2d 1, 3 (D.D.C. 2011), or under Rule
12(b)(1) if the complaint fails to allege facts sufficient to invoke the Court’s subject-matter
jurisdiction. This is such a case.
3 Most fundamentally, the complaint fails to comply with Rule 8(a) of the Federal Rules of
Civil Procedure, which requires “a short and plain statement of the claim showing that the
pleader is entitled to relief.” Fed. R. Civ. P. 8(a). This requirement “ensures that the opposing
party will receive ‘fair notice of what the . . . claim is and the grounds upon which it rests.’”
Jones v. Changsila, 271 F. Supp. 3d 9, 21 (D.D.C. 2017) (quoting Erickson v. Pardus, 551 U.S.
89, 93 (2007)). “Where a complaint is insufficiently focused, it places an undue burden on the
defendant to answer or move[,] and it invites unnecessary delay and confusion in the
proceedings.” Achagzai v. Broad. Bd. of Governors, 109 F. Supp. 3d 67, 71 (D.D.C. 2015).
Here, Plaintiff’s complaint contains a series of vague factual assertions and legal
conclusions. He alleges, for example, that the judicial Defendants engaged in a “pattern of
coordinated bias [that] severely compromised the integrity” of various proceedings. Dkt. 1 at 4
(Compl.). Even when considered liberally, the complaint offers no meaningful indication of
what happened or of why the alleged events, if accepted as true, would entitle Plaintiff to relief.
See Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 563 (2007). It includes, for example, vague
references to “Iranian intelligence,” Dkt. 1 at 2 (Compl.), to improper “political reach” and
“personal manipulation,” id. at 3 (Compl.), and to the Texas Dental Board’s “incompetence and
political bias,” id. These allegations are at times fantastical, and at other times are merely
disconnected or unexplained. As a result, Plaintiff’s complaint cannot withstand even minimal
scrutiny under Rules 8 and 12(b)(6).
Plaintiff’s complaint also fails to provide a sufficient basis for this Court to conclude that
it has subject-matter jurisdiction. Plaintiff bears the burden of establishing the Court’s
jurisdiction, Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992), and the Court has an ongoing
“obligation to assess its jurisdiction . . . sua sponte.” Friends of Animals v. U.S. Bureau of Land
4 Mgmt., 514 F. Supp. 3d 290, 299 (D.D.C. 2021); see also Fort Bend County v. Davis, 587 U.S.
541, 548 (2019) (a court “must consider” its subject-matter jurisdiction sua sponte “at any point
in the litigation”); Evans v. Suter, No. 09-5242, 2010 WL 1632902, at *1 (D.C. Cir. Apr. 2,
2010) (“[A] district court may dismiss a complaint sua sponte prior to service on the defendants
pursuant to Fed. R. Civ. P. 12(h)(3) when . . . it is evident that the court lacks subject matter
jurisdiction.”) (unpublished) (per curiam). Notably, the Court may sua sponte dismiss a
complaint if “its claims ‘are too insubstantial to invoke federal court jurisdiction.’” Lopez-Pena
v. Garland, 20-1889, 2021 WL 2188127, at *3 (D.D.C. May 28, 2021) (quoting Ord v. District
of Columbia, 587 F.3d 1136, 1144 (D.C. Cir. 2009)). Here, the international intelligence
conspiracy that Plaintiff alleges is too “fanciful” to sustain the Court’s jurisdiction. See id. at *4
(“An Article-III-wide conspiracy to unlawfully imprison individuals is ‘fanciful’ and
‘fictitious’—not factual.”).
Plaintiff also moves for a temporary restraining order, preliminary injunction, and
permanent injunction. Dkt. 5. Because the Court will dismiss the case, the Court will deny that
motion as moot.
CONCLUSION
The Court will, accordingly, DISMISS Plaintiff’s complaint, Dkt. 1, pursuant to Rules 8,
12(b)(1), and 12(b)(6) and will DENY Plaintiff’s motion for a temporary restraining order,
preliminary injunction, and permanent injunction, Dkt. 5, as moot.
A separate order shall issue.
/s/ Randolph D. Moss RANDOLPH D. MOSS United States District Judge
Date: May 19, 2025