UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
_________________________________________ ) GUANGLI ZHANG, et al. ) ) Plaintiffs, ) ) v. ) Civil No. 25-cv-02016 (APM) ) HOTEL FORTUNE, et al. ) ) Defendants. ) _________________________________________ )
MEMORANDUM OPINION
I.
Plaintiffs Guangli Zhang, Chengshuo Zhang, and Shanshuo Zhang, initiated this action
pro se against 30 defendants, including government officials, shelters, hospitals, physicians, and
state agencies. Plaintiffs bring a variety of claims, but their complaint centers on the alleged
kidnapping of their child by the Administration for Children’s Services (“ACS”) in New York
City. See Am. Compl., ECF No. 6 [hereinafter Compl.], at 11–13 (CM/ECF pagination). Plaintiffs
seek damages for physical injuries to their child, as well as the emotional injuries they suffered
because of the alleged kidnapping. See id. at 13. Plaintiffs also seek compensation for property
damage, lost wages, and fees paid. Id. For the following reasons, the court dismisses this matter
without prejudice.
II.
A.
“[F]ederal courts are without power to entertain claims otherwise within their jurisdiction
if they are so attenuated and unsubstantial as to be absolutely devoid of merit” or “obviously frivolous.” Hagans v. Lavine, 415 U.S. 528, 536–37 (1974) (internal quotation marks and citations
omitted); see also Tooley v. Napolitano, 586 F.3d 1006, 1009 (D.C. Cir. 2009) (“A complaint may
be dismissed on jurisdictional grounds when ‘it is patently insubstantial, presenting no federal
question suitable for decision.’” (internal quotation marks omitted) (quoting Best v. Kelly, 39 F.3d
328, 330 (D.C. Cir. 1994))). Claims are insubstantial and frivolous if they are “essentially
fictitious” because they advance, for example, “bizarre conspiracy theories.” Best, 39 F.3d at 330
(internal quotation marks and citations omitted). In such cases, a district court may dismiss the
case sua sponte. See Lewis v. Bayh, 577 F. Supp. 2d 47, 54 (D.D.C. 2008).
Plaintiffs’ complaint fails to raise a substantial federal question. Plaintiffs are residents of
Washington, D.C., who allege a broad conspiracy by Defendants to facilitate the kidnapping of
their child. See generally Compl. Plaintiffs claim, among other things, that: (1) ACS took
Plaintiffs’ child in January 2025 and offered no legal basis for doing so; (2) various state and local
officials, doctors, shelters, agencies, and hospitals in New York conspired with ACS to cover up
the alleged kidnapping; (3) the New York Office of the Ombudsman, within the Office of Children
and Family Services (“OCFS”), “condoned and protected illegal conduct” at a shelter where
Plaintiffs were living; and (4) the legal counsel assigned to Plaintiffs by the Center for Family
Representation, Inc. (“CFR”) aided the alleged conspiracy and offered ineffective assistance.
See id. at 11–13. Plaintiffs’ complaint also includes an exhibit containing figures of the damages
sought from the named Defendants, further allegations about Defendants’ “extremely cruel”
actions, allegations of threats received from the Chinese Communist Party, and four images of an
unidentified child’s face and head. See Compl., ECF No. 6, Ex. 1, ECF No. 6-1 [hereinafter Pls.’
Ex. 1] (CM/ECF pagination).
2 The court is mindful that complaints filed by pro se litigants are held to less stringent
standards than those applied to formal pleadings drafted by lawyers. See Haines v. Kerner,
404 U.S. 519, 520 (1972). But Plaintiffs’ claim is clearly fantastic, delusional, and “essentially
fictitious.” Best, 39 F.3d at 330 (internal quotation marks omitted). Accordingly, the court
dismisses the Complaint and this action for lack of subject matter jurisdiction as to all Defendants.
B.
Sua sponte dismissal is warranted for another reason: Plaintiffs fail to comply with Federal
Rule of Civil Procedure 8(a). That rule requires every complaint to include “a short and plain
statement of the claim showing that the pleader is entitled to relief” and that “[e]ach allegation of
a pleading be simple, concise, and direct.” Fed. R. Civ. P. 8(a), 8(d)(1). The D.C. Circuit has said
that “‘[t]aken together, Rules 8a(a) and 8([d])(1) underscore the emphasis placed on clarity and
brevity by the federal pleading rules’” and “[e]nforcing these rules is largely a matter for the trial
court’s discretion.” Ciralsky v. CIA, 355 F.3d 661, 669 (D.C.Cir.2004) (citations omitted).
Courts in this District have often dismissed complaints containing “an untidy assortment
of claims that are neither plainly nor concisely stated,” as well as those not “meaningfully
distinguished from bold conclusions, sharp harangues and personal comments.” Brown v.
Califano, 75 F.R.D. 497, 499 (D.D.C. 1977); see also Unfoldment, Inc. v. Dist. of Columbia,
No. 07-cv-1717 (HHK), 2007 WL 3125236, at *2 (D.D.C. Oct. 24, 2007) (dismissing case where
pleading filed by the plaintiff was “a confused and rambling narrative of charges and conclusions
concerning numerous persons, organizations and agencies” (internal citation omitted)). Similarly,
the D.C. Circuit has affirmed the sua sponte dismissal of a complaint that “does not provide fair
notice to the defendants of the claims against them, and as pled, . . . appears to be frivolous.”
3 See Karim-Panahi v. U.S. Congress, Senate and House of Representatives, 105 Fed. Appx. 270,
274 (D.C. Cir. 2004).
Plaintiffs’ pleading falls squarely within this class of complaints. It fails to identify the
“circumstances, occurrences, and events” supporting Plaintiffs’ claims for relief against each
Defendant. West v. Geithner, 427 F. App’x 9, 9 (D.C. Cir. 2011) (quoting Bell Atlantic Corp. v.
Twombly, 550 U.S. 544, 556 n.3 (2007)). It is simply “too convoluted and too confusing to require
Defendants to respond.” Rogler v. U.S. Dept. of Health & Hum. Servs., 620 F. Supp. 2d 123, 128
(D.D.C. 2009) (dismissing complaint advancing allegations having “nothing to do” with the legal
basis for plaintiff’s claims). Defendants therefore lack fair notice of their alleged wrongful acts.
Sua sponte dismissal is thus warranted.
Some Defendants have appeared and moved to dismiss under Rule 12(b)(2) for lack of
personal jurisdiction. See Wang Defs.’ Mot. to Dismiss, or in the Alt., for a More Definite Stmt.,
ECF No. 4; Defs. LIJ Forest Hills & Dr. Popso’s Mot. to Dismiss, ECF No. 10; Defs. Forestdale,
Inc. & Crystal Zhang’s Mot. to Dismiss, ECF No. 16; Defs. Center for Family Representation Inc.
& Kaitlan Moe’ Mot. to Dismiss the Compl., ECF No. 27. To survive a Rule 12(b)(2) motion to
dismiss, a plaintiff must “make a prima facie showing of the pertinent jurisdictional facts.”
First Chicago Int’l. v. United Exch. Co., 836 F.2d 1375, 1378 (D.C. Cir.
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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
_________________________________________ ) GUANGLI ZHANG, et al. ) ) Plaintiffs, ) ) v. ) Civil No. 25-cv-02016 (APM) ) HOTEL FORTUNE, et al. ) ) Defendants. ) _________________________________________ )
MEMORANDUM OPINION
I.
Plaintiffs Guangli Zhang, Chengshuo Zhang, and Shanshuo Zhang, initiated this action
pro se against 30 defendants, including government officials, shelters, hospitals, physicians, and
state agencies. Plaintiffs bring a variety of claims, but their complaint centers on the alleged
kidnapping of their child by the Administration for Children’s Services (“ACS”) in New York
City. See Am. Compl., ECF No. 6 [hereinafter Compl.], at 11–13 (CM/ECF pagination). Plaintiffs
seek damages for physical injuries to their child, as well as the emotional injuries they suffered
because of the alleged kidnapping. See id. at 13. Plaintiffs also seek compensation for property
damage, lost wages, and fees paid. Id. For the following reasons, the court dismisses this matter
without prejudice.
II.
A.
“[F]ederal courts are without power to entertain claims otherwise within their jurisdiction
if they are so attenuated and unsubstantial as to be absolutely devoid of merit” or “obviously frivolous.” Hagans v. Lavine, 415 U.S. 528, 536–37 (1974) (internal quotation marks and citations
omitted); see also Tooley v. Napolitano, 586 F.3d 1006, 1009 (D.C. Cir. 2009) (“A complaint may
be dismissed on jurisdictional grounds when ‘it is patently insubstantial, presenting no federal
question suitable for decision.’” (internal quotation marks omitted) (quoting Best v. Kelly, 39 F.3d
328, 330 (D.C. Cir. 1994))). Claims are insubstantial and frivolous if they are “essentially
fictitious” because they advance, for example, “bizarre conspiracy theories.” Best, 39 F.3d at 330
(internal quotation marks and citations omitted). In such cases, a district court may dismiss the
case sua sponte. See Lewis v. Bayh, 577 F. Supp. 2d 47, 54 (D.D.C. 2008).
Plaintiffs’ complaint fails to raise a substantial federal question. Plaintiffs are residents of
Washington, D.C., who allege a broad conspiracy by Defendants to facilitate the kidnapping of
their child. See generally Compl. Plaintiffs claim, among other things, that: (1) ACS took
Plaintiffs’ child in January 2025 and offered no legal basis for doing so; (2) various state and local
officials, doctors, shelters, agencies, and hospitals in New York conspired with ACS to cover up
the alleged kidnapping; (3) the New York Office of the Ombudsman, within the Office of Children
and Family Services (“OCFS”), “condoned and protected illegal conduct” at a shelter where
Plaintiffs were living; and (4) the legal counsel assigned to Plaintiffs by the Center for Family
Representation, Inc. (“CFR”) aided the alleged conspiracy and offered ineffective assistance.
See id. at 11–13. Plaintiffs’ complaint also includes an exhibit containing figures of the damages
sought from the named Defendants, further allegations about Defendants’ “extremely cruel”
actions, allegations of threats received from the Chinese Communist Party, and four images of an
unidentified child’s face and head. See Compl., ECF No. 6, Ex. 1, ECF No. 6-1 [hereinafter Pls.’
Ex. 1] (CM/ECF pagination).
2 The court is mindful that complaints filed by pro se litigants are held to less stringent
standards than those applied to formal pleadings drafted by lawyers. See Haines v. Kerner,
404 U.S. 519, 520 (1972). But Plaintiffs’ claim is clearly fantastic, delusional, and “essentially
fictitious.” Best, 39 F.3d at 330 (internal quotation marks omitted). Accordingly, the court
dismisses the Complaint and this action for lack of subject matter jurisdiction as to all Defendants.
B.
Sua sponte dismissal is warranted for another reason: Plaintiffs fail to comply with Federal
Rule of Civil Procedure 8(a). That rule requires every complaint to include “a short and plain
statement of the claim showing that the pleader is entitled to relief” and that “[e]ach allegation of
a pleading be simple, concise, and direct.” Fed. R. Civ. P. 8(a), 8(d)(1). The D.C. Circuit has said
that “‘[t]aken together, Rules 8a(a) and 8([d])(1) underscore the emphasis placed on clarity and
brevity by the federal pleading rules’” and “[e]nforcing these rules is largely a matter for the trial
court’s discretion.” Ciralsky v. CIA, 355 F.3d 661, 669 (D.C.Cir.2004) (citations omitted).
Courts in this District have often dismissed complaints containing “an untidy assortment
of claims that are neither plainly nor concisely stated,” as well as those not “meaningfully
distinguished from bold conclusions, sharp harangues and personal comments.” Brown v.
Califano, 75 F.R.D. 497, 499 (D.D.C. 1977); see also Unfoldment, Inc. v. Dist. of Columbia,
No. 07-cv-1717 (HHK), 2007 WL 3125236, at *2 (D.D.C. Oct. 24, 2007) (dismissing case where
pleading filed by the plaintiff was “a confused and rambling narrative of charges and conclusions
concerning numerous persons, organizations and agencies” (internal citation omitted)). Similarly,
the D.C. Circuit has affirmed the sua sponte dismissal of a complaint that “does not provide fair
notice to the defendants of the claims against them, and as pled, . . . appears to be frivolous.”
3 See Karim-Panahi v. U.S. Congress, Senate and House of Representatives, 105 Fed. Appx. 270,
274 (D.C. Cir. 2004).
Plaintiffs’ pleading falls squarely within this class of complaints. It fails to identify the
“circumstances, occurrences, and events” supporting Plaintiffs’ claims for relief against each
Defendant. West v. Geithner, 427 F. App’x 9, 9 (D.C. Cir. 2011) (quoting Bell Atlantic Corp. v.
Twombly, 550 U.S. 544, 556 n.3 (2007)). It is simply “too convoluted and too confusing to require
Defendants to respond.” Rogler v. U.S. Dept. of Health & Hum. Servs., 620 F. Supp. 2d 123, 128
(D.D.C. 2009) (dismissing complaint advancing allegations having “nothing to do” with the legal
basis for plaintiff’s claims). Defendants therefore lack fair notice of their alleged wrongful acts.
Sua sponte dismissal is thus warranted.
Some Defendants have appeared and moved to dismiss under Rule 12(b)(2) for lack of
personal jurisdiction. See Wang Defs.’ Mot. to Dismiss, or in the Alt., for a More Definite Stmt.,
ECF No. 4; Defs. LIJ Forest Hills & Dr. Popso’s Mot. to Dismiss, ECF No. 10; Defs. Forestdale,
Inc. & Crystal Zhang’s Mot. to Dismiss, ECF No. 16; Defs. Center for Family Representation Inc.
& Kaitlan Moe’ Mot. to Dismiss the Compl., ECF No. 27. To survive a Rule 12(b)(2) motion to
dismiss, a plaintiff must “make a prima facie showing of the pertinent jurisdictional facts.”
First Chicago Int’l. v. United Exch. Co., 836 F.2d 1375, 1378 (D.C. Cir. 1988) (collecting cases).
The complaint “must allege specific acts connecting the defendants with the forum.” Second
Amend. Found. v. U.S. Conf. of Mayors, 274 F.3d 521, 524 (D.C. Cir. 2001) (cleaned up). A “bare
allegation of conspiracy or agency” does not establish personal jurisdiction. Id. (internal quotation
marks and citation omitted).
4 Plaintiffs fail to establish that this court has personal jurisdiction over any moving
Defendant. Movants are all citizens of New York. All the alleged conduct occurred in New York,
and Plaintiffs offer no theory of how Defendants’ alleged actions caused them injury in the District
of Columbia. See Compl. at 11–13 (CM/ECF pagination) (alleging Defendants were “derelict in
[their] duty,” “condone[d] and shield[ed]” the alleged perpetrators, and “committed a crime,” but
asserting no connection to the District). The court therefore lacks both general jurisdiction and
specific jurisdiction under the D.C. long-arm statute, D.C. Code § 13-423. Further, Plaintiffs
allege a sweeping conspiracy, but identify no act occurring in the District of Columbia.
See FC Inv. Grp. LC v. IFX Mkts., Ltd., 529 F.3d 1087, 1096 (D.C. Cir. 2008) (setting forth
elements of conspiracy jurisdiction). They therefore cannot avail themselves of personal
jurisdiction by an alleged civil conspiracy. See Dyson v. Dutko Ragen Homes & Invs., No. 21-cv-
2280 (APM), 2022 WL 1294484, at *6 (D.D.C. Apr. 27, 2022) (granting defendants’ motion to
dismiss because plaintiff failed to plead facts demonstrating defendants’ participation in a civil
conspiracy within the forum).
The court therefore grants the moving Defendants’ motions to dismiss for lack of personal
jurisdiction.
IV.
For the foregoing reasons, the Complaint and this action are hereby dismissed. All motions
to dismiss, ECF Nos. 4, 10, 16, & 27, are granted. Plaintiffs’ outstanding motions, ECF Nos. 2,
13, 14, & 22, are denied as moot. The court declines to grant Plaintiffs leave to amend because
5 they have offered no basis for personal jurisdiction as to any Defendant. The court does not,
however, dismiss the action with prejudice, as suit may be appropriate in a different forum.
A final, appealable order accompanies this Memorandum Opinion.
Dated: October 7, 2025 Amit P. Mehta United States District Judge