Brown v. United States Department of Education Office of Inspector General, 2:25-cv-00668

Plaintiff, Elizabeth Brenda Brown, filed a pro se lawsuit in forma pauperis against the U.S. Department of Education's Office of Inspector General (DOE OIG).
Brown alleges that DOE OIG failed to investigate and prosecute her daughter for allegedly forging Brown’s signature on a FAFSA application in 2016.
Brown claims this failure led to a series of harms, including her own hospitalizations related to mental health.
The complaint left the jurisdiction section blank, did not cite a legal cause of action or any constitutional violation, and sought $6,000,000 in damages.
The DOE OIG, a federal agency, is generally immune from suits for damages unless immunity is waived.
The Court reviewed the complaint under 28 U.S.C. § 1915(e)(2)(B) and identified several deficiencies but allowed Brown 21 days to amend her complaint.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction basis	No basis stated	Not addressed	Complaint fails to state jurisdiction basis
Sovereign immunity	Sued DOE OIG for monetary relief	DOE OIG is immune absent waiver	Agency immune; suit not allowed unless waiver exists
Failure to state a legal claim	Claims DOE OIG failed to serve justice	Not addressed	No cognizable legal theory or constitutional claim
Prosecutorial discretion	DOE OIG failed to investigate/prosecute	Agencies have broad discretion, limited only by discrimination	No impermissible basis for non-prosecution alleged

Ashcroft v. Iqbal, 556 U.S. 662 (Rule 8 pleading standard requires more than conclusory statements)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Plausibility standard for stating a claim)
Erickson v. Pardus, 551 U.S. 89 (Pro se pleadings to be liberally construed)
F.D.I.C. v. Meyer, 510 U.S. 471 (Sovereign immunity shields federal agencies from suit)
United States v. Armstrong, 517 U.S. 456 (Government discretion in prosecution decisions)
Wayte v. United States, 470 U.S. 598 (Limits on judicial review of prosecution decisions)