Byrd-Sanders v. Fedchoice Federal Credit Union
Civil Action No. 2017-0627
| D.D.C. | Jun 12, 2017Background
- Plaintiff Donetta Michelle Byrd‑Sanders, proceeding pro se, filed a one‑page handwritten complaint with nine pages of bank receipts alleging unauthorized withdrawals from her FedChoice account.
- Attached receipts show multiple withdrawals from an account in the name “Donetta Byrd,” each annotated by plaintiff as "not my transaction" or "not my signature."
- Plaintiff alleges she suffers from a mental disability and that another individual exploited her to make the withdrawals; she references a police report (No. 150519) and contact with a fraud department.
- The complaint contains no clear statement of the court’s basis for jurisdiction and few material factual allegations about how the credit union acted wrongfully.
- Defendant FedChoice moved to dismiss for lack of subject‑matter jurisdiction and failure to state a claim; the court dismissed the complaint sua sponte for failure to comply with Federal Rule of Civil Procedure 8.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether complaint satisfies Rule 8(a)’s pleading requirements | Byrd‑Sanders alleges unauthorized withdrawals and mental incapacity but provides minimal factual detail | FedChoice argued dismissal for jurisdictional/merits defects (mtn to dismiss) | Complaint dismissed for failing to provide a short, plain statement of jurisdiction and claim under Rule 8(a) |
| Whether court had subject‑matter jurisdiction | Complaint did not specify federal question or diversity basis; plaintiff did not plead jurisdictional facts | FedChoice challenged jurisdiction in its motion to dismiss | Court found jurisdictional basis unclear and Rule 8 failure warranted dismissal without reaching merits |
| Whether pro se status relaxes pleading standards enough to survive dismissal | Plaintiff relied on pro se status and attached receipts to allege wrongs | Defendant relied on rules and motion practice; urged dismissal | Court noted pro se pleadings held to less stringent standards but still must comply with the Federal Rules; pro se status did not salvage the deficient complaint |
| Whether factual allegations put defendant on notice of claim | Plaintiff submitted receipts and brief narrative about police report and fraud | Defendant argued the complaint lacked factual allegations showing FedChoice’s wrongful conduct | Court held allegations were insufficient to notify defendant of the basis for a claim; dismissal required |
Key Cases Cited
- Butler v. Cal. St. Disbursement Unit, 990 F. Supp. 2d 8 (D.D.C. 2013) (Rule 8’s notice‑pleading purpose and requirement that pleadings give fair notice to the defendant)
- Moore v. Agency for Int’l Dev., 994 F.2d 874 (D.C. Cir. 1993) (pro se pleadings are construed liberally but must comply with procedural rules)
- James v. United States, 48 F. Supp. 3d 58 (D.D.C. 2014) (drawing reasonable inferences in favor of the plaintiff at the pleading stage)