ADAMS v. UNITED STATES DEPARTMENT OF ARMY
1:19-cv-02188
D.D.C.Aug 13, 2019Background
- Pro se plaintiff Dale B. Adams filed a complaint alleging childhood events, electronic surveillance by the CIA, and deficient medical treatment causing irreparable harm, naming the CIA, its Director and employees, and the Department of the Army and its Secretary.
- Complaint referenced the Administrative Procedure Act (APA) and the Freedom of Information Act (FOIA), but did not identify the specific agency actions or records challenged.
- Plaintiff also mentioned First Amendment concerns and sought relief on behalf of unnamed "Silent Parties."
- The district court reviewed the pleadings under the standards for pro se litigants but emphasized that pro se status does not relieve compliance with the Federal Rules of Civil Procedure, including Rule 8(a).
- The court found the complaint vague, conclusory, and failing to state a plausible claim under Ashcroft v. Iqbal/Twombly pleading standards; it also noted a pro se litigant cannot represent others.
- Court granted in forma pauperis status, denied the plaintiff's motions without prejudice, and dismissed the complaint without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of pleading under Rule 8(a) and Iqbal/Twombly | Adams alleged agency misconduct, surveillance, and mistreatment sufficient to state claims | Defendants argued pleadings must meet Rule 8 and plausibility standards to give fair notice | Court: Complaint is too vague and conclusory; fails to state a plausible claim; dismissed without prejudice |
| APA / identification of agency action challenged | Adams invoked APA review generally | Defendants required clear identification of the agency action or failure to act being challenged | Court: Plaintiff failed to identify the specific agency action; APA claim inadequate |
| FOIA relief / request for agency records | Adams referenced FOIA in alleging First Amendment violation and sought records/relief | Defendants would require a clear FOIA claim and identification of withheld records | Court: FOIA relief not properly pleaded or clarified; claim insufficient |
| Representation of others by pro se litigant | Adams sought relief on behalf of "Silent Parties" | Defendants asserted pro se may only proceed personally | Court: Pro se litigant cannot represent others; claims on behalf of others dismissed |
Key Cases Cited
- Haines v. Kerner, 404 U.S. 519 (pro se pleadings held to less stringent standards)
- Jarrell v. Tisch, 656 F. Supp. 237 (D.D.C. 1987) (pro se litigants must comply with Federal Rules)
- Brown v. Califano, 75 F.R.D. 497 (D.D.C. 1977) (Rule 8 notice purpose: permit defense and res judicata analysis)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for pleading; must plead facts to infer liability)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (setting the pleading standard referenced in Iqbal)