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Alejandro v. State of California
Civil Action No. 2022-0899
| D.D.C. | May 6, 2022
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Background

  • Pro se plaintiff Omar Medina Alejandro (also filed as Omar Alejandro Medina) filed a cryptic complaint and IFP application in D.D.C., suing the State of California for alleged harassment at his home and asserted Fourth Amendment violations.
  • Complaint is largely incoherent: alleges male voices, harassment by "homosexuals," stroke-like symptoms, and demands exorbitant damages (e.g., $150 million, conditional $8 trillion).
  • Plaintiff also filed a motion for emergency relief seeking expedited handling, citing PACER access costs and lack of funds.
  • The Court found the pleading fails to provide notice or plausible factual allegations and is legally unintelligible under Fed. R. Civ. P. 8(a).
  • The filing joins a long pattern: plaintiff has filed dozens of largely duplicative/frivolous cases in this and other federal courts, many dismissed on screening.
  • Court dismissed the complaint, denied emergency relief, and ordered plaintiff to show cause why he should not be barred from proceeding in forma pauperis in future filings.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Rule 8 sufficiency — does complaint state a plausible claim? Complaint alleges harassment and Fourth Amendment violation at home. No coherent factual allegations linking California to wrongdoing; pleading fails to give fair notice. Dismissed for failure to satisfy Rule 8(a); complaint is unintelligible and provides no basis for relief.
Emergency relief / expedited handling Requests expedition because PACER costs and inability to buy a weapon; seeks urgent attention. No substantive basis shown for emergency relief; motion incomprehensible. Emergency motion denied as implausible and unintelligible.
Subject-matter jurisdiction over frivolous/insubstantial claims Seeks federal relief for alleged harassment. Court: frivolous or wholly incredible claims do not invoke federal jurisdiction. Court concluded the complaint is frivolous/insubstantial and lacks a cognizable federal claim; dismissed.
Abuse of in forma pauperis privilege; prospective bar? Implied need to proceed IFP given lack of funds. Court points to plaintiff's repetitive, frivolous filings and administrative burden. Court found an abusive pattern and ordered plaintiff to show cause before imposing a prospective bar on IFP filings in the district.

Key Cases Cited

  • Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must contain factual matter showing a plausible claim).
  • Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standard requiring allegations that plausibly suggest entitlement to relief).
  • Neitzke v. Williams, 490 U.S. 319 (1989) (frivolous suits lack arguable basis in law or fact).
  • Denton v. Hernandez, 504 U.S. 25 (1992) (complaints that are irrational or wholly incredible may be dismissed as frivolous).
  • Crisafi v. Holland, 655 F.2d 1305 (D.C. Cir. 1981) (abusive complaints may be deemed malicious).
  • Hagans v. Lavine, 415 U.S. 528 (1974) (federal courts lack power to entertain claims that are attenuated or unsubstantial).
  • Butler v. Dep't of Justice, 492 F.3d 440 (D.C. Cir. 2007) (factors for revoking IFP privilege and assessing abusive filing patterns).
  • Hurt v. Social Security Admin., 544 F.3d 308 (D.C. Cir. 2008) (upholding prospective revocation of IFP privileges for abusive filers).
  • In re Powell, 851 F.2d 427 (D.C. Cir. 1988) (court must make findings and allow response before imposing filing restrictions).
  • Urban v. United Nations, 768 F.2d 1497 (D.C. Cir. 1985) (courts may protect orderly administration of justice).
  • In re Martin-Trigona, 737 F.2d 1254 (2d Cir. 1984) (injunctive remedies to protect court integrity).
  • Jarrell v. Tisch, 656 F. Supp. 237 (D.D.C. 1987) (pro se litigants must comply with the Federal Rules of Civil Procedure).
Read the full case

Case Details

Case Name: Alejandro v. State of California
Court Name: District Court, District of Columbia
Date Published: May 6, 2022
Docket Number: Civil Action No. 2022-0899
Court Abbreviation: D.D.C.