Witchard v. Surampudi

CourtDistrict Court, District of Columbia
DecidedMarch 27, 2025
DocketCivil Action No. 2024-0296
StatusPublished

This text of Witchard v. Surampudi (Witchard v. Surampudi) 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
Witchard v. Surampudi, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JOSEPH WITCHARD,

Plaintiff,

v. No. 24-cv-00296 (DLF)

VIJAYA S. SURAMPUDI, et al.,

Defendant.

MEMORANDUM OPINION AND ORDER

Joseph Witchard, a prisoner proceeding pro se, brings this action against various federal

defendants for alleged constitutional violations relating to proceedings in the United States Court

of Federal Claims and the United States Court of Appeals for the Federal Circuit. Compl., Dkt. 1.

Before the Court are the defendants’ Motion to Dismiss, Dkt. 21, and the plaintiff’s Motion for

Summary Judgment, Dkt. 22. For the reasons that follow, the Court will grant the defendants’

motion to dismiss and deny the plaintiff’s motion as moot.

I. BACKGROUND

In 2014, Witchard was convicted of nine counts of mail fraud, six counts of filing false

claims, six counts of theft of government property, and nine counts of aggravated identity theft in

the United States District Court for the Middle District of Florida. See Compl. ¶ 7; United States

v. Witchard, No. 6:14-cr-112-RBD-GJK-1 (M.D. Fla.); United States v. Witchard, 646 F. App’x

793, 794 (11th Cir. 2016). He was sentenced to a 331-month term of imprisonment. See Compl.

¶ 7. In 2016, the United States Court of Appeals for the Eleventh Circuit affirmed his conviction

and sentence on direct review. See Witchard, 646 F. App’x at 793–99. Since then, Witchard has unsuccessfully attempted to overturn his conviction and sentence in a plethora of courts. 1 This

action arises out of one of those attempts.

In December 2022, Witchard filed a civil complaint in the United States Court of Federal

Claims alleging “unjust convictions and imprisonment” and seeking money damages, as well as

an injunction that would effect his immediate release from prison. See Compl. at 8–10. The case

was assigned to the Honorable Matthew H. Solomson, who proceeded to enter an indefinite stay

due to the court potentially lacking jurisdiction. See id. at 9; Order, Witchard v. United States, No.

22-cv-1818 (Fed. Cl. Dec. 22, 2022). On February 15, 2023, Witchard filed a motion for entry of

default, and on February 24, 2023, he filed a motion for final judgment of default. See Compl. at

9. On February 27, 2023, Vijaya S. Surampudi, a Department of Justice Trial Attorney, entered a

notice of appearance on behalf of the United States. Id. The next day, Surampudi asked for a

clarification of the stay order, see id. at 10. The court reiterated that the case is stayed and that the

United States did not need to file a response to the complaint until further order of the court. See

Order, Witchard v. United States, No. 22-cv-1818 (Fed. Cl. Mar. 1, 2023). On April 3, 2023, the

court again reiterated that the case is stayed, and denied Witchard’s motions for default judgment

without prejudice. See Order, Witchard v. United States, No. 22-cv-1818 (Fed. Cl. Apr. 3, 2023).

Witchard alleges that Judge Solomson and Surampudi conspired to “induc[e] a deputy clerk or

other court official to make a ‘false docket’ entry on the Court records of [Witchard’s] case” in

order to achieve the denial of his motion for final default judgment. Compl. at 10.

On April 5, 2023, Witchard sought a petition for writ of mandamus from the Court of

Appeals for the Federal Circuit on the grounds that Judge Solomson engaged in “judicial

1 While the Court presents only the litigation history directly relevant to this action, a thorough summary of Witchard’s extensive activity in the courts may be found in Witchard v. United States, 165 Fed. Cl. 125, 128–32 (2023).

2 usurpation of authority” by “not granting [Witchard] his entitlement to a final judgment of default.”

Compl. at 10. The Federal Circuit denied the motion on October 13, 2023. Id. Witchard then

filed a motion for a panel rehearing, which was also denied. Id. Witchard alleges that these denials

were also the result of a conspiracy between Judge Solomson and Surampudi to induce circuit

clerks or other officials to issue fraudulent orders. See id. at 10–11.

Judge Solomson ultimately dismissed Witchard’s complaint on April 14, 2023, which

Witchard alleges was an act of retaliation. See id. at 10. In sum, Witchard alleges that Judge

Solomson’s and Surampudi’s actions were fraudulent and calculated “to rob and disallow

Plaintiff’s his [sic] constitutional and civil rights to the unjust conviction and imprisonment claim

previously filed by him.” Id. at 11.

Witchard filed the instant action on January 30, 2024, naming as defendants Judge

Solomson, Surampudi, the United States Attorney General’s Office, the Office of the General

Counsel, the Administrative Office of the United States Courts, and other unknown named

defendants (collectively, the federal defendants). Dkt. 1. He brings three Bivens claims for (1)

“denial of affective [sic] access to the court and the right to petition the court” in violation of the

First Amendment; (2) “denial of the right to be free from illegal seizure of his liberty” in violation

of the Fourth Amendment; and (3) “denial of due process and equal protection of the law” in

violation of the Fifth Amendment. Compl. at 12–13. Witchard seeks $50,000,000 in damages, as

well as a “mandatory preliminary and permanent injunction, enjoining [Witchard’s] heretofore

unconstitutionally imposed federal prison sentence.” Compl. at 13–14. The federal defendants

moved to dismiss, Dkt. 21, and Witchard moved for summary judgment, Dkt. 22.

3 II. LEGAL STANDARDS

Under Federal Rule of Civil Procedure 12(b)(1), a defendant may move to dismiss an action

for lack of subject-matter jurisdiction. Fed. R. Civ. P. 12(b)(1). Because “[s]overeign immunity

is jurisdictional in nature,” FDIC v. Meyer, 510 U.S. 471, 475 (1994), claims barred by the United

States’ sovereign immunity are “subject to dismissal under Rule 12(b)(1),” Clayton v. District of

Columbia, 931 F. Supp. 2d 192, 200 (D.D.C. 2013). When reviewing a motion to dismiss for lack

of jurisdiction, the court must “assume the truth of all material factual allegations in the complaint

and construe the complaint liberally.” Am. Nat. Ins. Co. v. FDIC, 642 F.3d 1137, 1139 (D.C. Cir.

2011) (internal quotation marks omitted). At the same time, plaintiffs bear the burden of

establishing subject-matter jurisdiction, see Arpaio v. Obama, 797 F.3d 11, 19 (D.C. Cir. 2015),

and courts must raise obstacles to their jurisdiction sua sponte, see Fort Bend Cnty. v. Davis, 587

U.S. 541, 548 (2019). “[W]hile complaints filed by pro se litigants are held to less stringent

standards than those applied to formal pleadings drafted by lawyers, even a pro se plaintiff bears

the burden of establishing that the Court has subject matter jurisdiction.” Newby v. Obama, 681

F. Supp. 2d 53, 55 (D.D.C. 2010) (cleaned up).

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