Woodall v. Trump

• Court: District Court, District of Columbia
• Decided: June 17, 2025
• Docket: Civil Action No. 2025-0112
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

NICHOLAS WOODALL, ) ) Plaintiff, ) ) Civil Action No. 1: 25-cv-00112 (UNA) v. ) ) ) DONALD J. TRUMP, et al., ) ) ) Defendants. )

MEMORANDUM OPINION

Plaintiff Nicholas Woodall filed this matter on January 15, 2025, and sought, several times

unsuccessfully, to file this matter under seal and under pseudonym. Ultimately, plaintiff

determined to proceed with this case on the public docket, and on May 12, 2025, plaintiff filed the

operative amended petition (“Am. Pet.”), ECF No. 13, under his real name. The court may now

preliminarily review this matter. Upon review, the court grants plaintiff’s pending application for

leave to proceed in forma pauperis, ECF No. 16, and for the reasons explained below, this matter

is dismissed without prejudice.

Plaintiff, a resident of Michigan, presents a chockablock amended “petition for

grievances.” See generally Am. Pet. He sues the President of the United States, the Speaker of

the U.S. House of Representatives, the President pro tempore of the United States Senate, the U.S.

Supreme Court, the Executive Office for United States Attorneys, and the Attorney General for

the District of Columbia. See id. at 2–3. The amended petition is rambling and difficult to follow,

comprised largely of cryptic ruminations, hypothetical questions, and obscure and irrelevant

references. See id. at 4–34. At root, plaintiff challenges his limited access, as a pro se litigant, to

federal law libraries and their materials and he further contends that, given the unlimited access afforded to attorneys barred in those jurisdictions, he has suffered an unfairness that violates his

constitutional rights. See id. at 9–30. He asks for assorted damages and equitable relief, including

for this court to “define” the appropriate level of access for pro se and indigent litigants to federal

law libraries. See id. at 31.

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 here, the amended petition fails to comply with Rule

8(a) of the Federal Rules of Civil Procedure, which requires a pleading 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, 678-79 (2009); Ciralsky v. CIA, 355 F.3d 661, 668-71 (D.C. Cir. 2004). The Rule 8

standard ensures that defendants receive fair 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). The amended petition

is neither short nor plain, see Fed. R. Civ. P. 8(a), the allegations cannot be described as simple,

concise, and direct, see Fed. R. Civ. P. 8(d)(1), and the paragraphs are not limited to a single set

of circumstances, see Fed. R. Civ. P. 10(b).

When, as here, a pleading “contains an untidy assortment of claims that are neither plainly

nor concisely stated, nor meaningfully distinguished from bold conclusions, sharp harangues and

personal comments [,]” it does not fulfill the requirements of Rule 8. Jiggetts v. Dist. of Columbia,

319 F.R.D. 408, 413 (D.D.C. 2017), aff’d sub nom. Cooper v. Dist. of Columbia, No. 17-7021,

2017 WL 5664737 (D.C. Cir. Nov. 1, 2017). And “[a] confused and rambling narrative of charges

and conclusions . . . does not comply with the requirements of Rule 8.” Cheeks v. Fort Myer Constr. Corp., 71 F. Supp. 3d 163, 169 (D.D.C. 2014) (citation and internal quotation marks

omitted). Plaintiff’s amended petition falls squarely into this category.

In any event, insofar as plaintiff alleges that his lack of access to federal law libraries has

infringed on his constitutional rights, he has failed to state a claim. Indeed, this court is not in a

position to explore the parameters of his right of such access to law libraries, because the Supreme

Court has already held that there is none. See Lewis v. Casey, 518 U.S. 343, 351 (1996); see also

Woodwall v. United States, No. 24-cv-1410, 2024 WL 4839396, at *3 (N.D. Ohio Nov. 20, 2024)

(explaining same to Woodall, and dismissing another substantially similar lawsuit that he filed in

another jurisdiction for failure to state a claim). Simply put, “[e]vents may not have unfolded as

plaintiff wished, but his dissatisfaction . . . [does] not form a basis” for a constitutional violation,

Melton v. Dist. of Columbia, 85 F. Supp. 3d 183, 193 (D.D.C. 2015).

Accordingly, this matter is dismissed without prejudice. A separate order accompanies

this memorandum opinion.

__________/s/_____________ Date: June 17, 2025 AMIT P. MEHTA United States District Judge