Zeigler v. Trump

• Court: District Court, District of Columbia
• Decided: January 13, 2025
• Docket: Civil Action No. 2024-3545
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JOHN ZEIGLER, ) ) Plaintiff, ) ) v. ) Civil Action No. 24-3545 (UNA) ) DONALD JOHN TRUMP, ) ) Defendant. )

Memorandum Opinion

This matter is before the Court on Plaintiff’s application to proceed in forma pauperis and

his pro se “Complaint for Emergency Action for Quo Warranto.” The application will be granted,

and the complaint will be dismissed for lack of subject matter jurisdiction.

“Article III of the Constitution limits the judicial power to deciding ‘Cases’ and

‘Controversies.’” In re Navy Chaplaincy, 534 F.3d 756, 759 (D.C. Cir. 2008) (quoting U.S. Const.

art. III, § 2). “One element of the case-or-controversy requirement is that plaintiffs must establish

that they have standing to sue.” Comm. on Judiciary of U.S. House of Representatives v. McGahn,

968 F.3d 755, 762 (D.C. Cir. 2020) (internal quotation marks and citation omitted). A party has

standing for purposes of Article III if he has “(1) suffered an injury in fact, (2) that is fairly

traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a

favorable judicial decision.” Id. at 763 (quoting Spokeo, Inc. v. Robins, 578 U.S. 330, 338 (2016)).

“This case arises from Public Law 115-427, which the Defendant, Donald John Trump,

signed into law on January 9, 2019.” ECF No. 1 at 1. Plaintiff describes Section 6 of Public Law

115-427 as a delegation of authority “to the State Department . . . to assess, determine, and act

upon foreign governments’ compliance with ‘minimum standards’ for the elimination of

trafficking, as outlined in Section 110(b) of the Victims of Trafficking and Violence Protection Act of 2000.” Id. According to Plaintiff, this delegation of authority violates the Commerce Clause

of the United States Constitution, and “[b]y signing Public Law 115-427 into law, the

Defendant . . . enabled an unconstitutional act, thereby violating his oath . . . of [o]ffice.” Id. at 2.

Plaintiff demands that Defendant “provide to this Honorable Court by what authority [he] signed

Public Law 115-427 into law, despite its clear contradiction to the Constitution of the United

States.” Id.

Missing from the complaint are any factual allegations establishing that Plaintiff sustained

(or is likely to sustain) an injury resulting from Defendant’s actions. “[A] plaintiff raising only a

generally available grievance about government—claiming only harm to his and every citizen’s

interest in proper application of the Constitution and laws, and seeking relief that no more directly

and tangibly benefits him than it does the public at large—does not state an Article III case or

controversy.” Lujan v. Defenders of Wildlife, 504 U.S. 555, 573–74 (1992). Because Plaintiff fails

to allege facts sufficient to establish standing, the Court lacks subject matter jurisdiction over his

claims. The complaint must therefore be dismissed without prejudice.

A separate order consistent with this decision accompanies this memorandum opinion.

AMIR H. ALI United States District Judge Date: January 10, 2025