CAVIENSS v. UNITED STATES
1:25-cv-01157
| D.D.C. | Jun 18, 2025Background
- Plaintiff, Stanley A. Cavienss, Jr., filed a pro se action in the D.C. District Court, naming various federal officials and judicial officers involved in a prior employment discrimination case he litigated in Connecticut (Cavienss I).
- The current filing, considered an amended complaint by the court, reasserts and expands claims from the previous case, targeting judges, court staff, and counsel from Cavienss I and the Second Circuit.
- Plaintiff seeks relief under multiple theories: constitutional violations (primarily via Bivens), review and reversal of prior federal rulings, and as a purported whistleblower under the False Claims Act.
- Plaintiff's amended complaint is described by the court as confusing, lacking factual detail, and noncompliant with procedural rules (notably, Rule 8(a)).
- The court granted the plaintiff leave to proceed in forma pauperis but dismissed the complaint without prejudice, also denying his related motions for the same underlying defects.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper Pleading under Rule 8 | Submission suffices as operative complaint | Complaint lacks clarity, fails procedural rules | Dismissed for failure to comply with Rule 8 |
| Review of Earlier Federal Judgments | Court should overturn prior unfavorable decisions | Court lacks authority to review other courts | No jurisdiction over other federal courts’ orders |
| Bivens Action Against Federal Officials | Broad allegations of constitutional violations | Claims are broad, no damages sought | No Bivens claim stated, especially vs. US |
| Pro Se Qui Tam/Whistleblower Standing | Can act on behalf of US as a whistleblower | Pro se cannot bring qui tam action | Pro se relators cannot maintain qui tam actions |
| Judicial Misconduct Reporting | District Court should act on judicial misconduct claims | Jurisdiction/procedure lies elsewhere | District Court has no power—file with circuit |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleadings must state plausible claims for relief)
- Bivens v. Six Unknown Fed. Narcotics Agents, 403 U.S. 388 (1971) (judicially created damages action for constitutional violations by federal agents)
- Davis v. Passman, 442 U.S. 228 (1979) (in Bivens actions, damages are the exclusive remedy against officials)
- Federal Deposit Ins. Corp. v. Meyer, 510 U.S. 471 (1994) (Bivens does not extend to federal agencies)
- Ciralsky v. CIA, 355 F.3d 661 (D.C. Cir. 2004) (Rule 8 requires clear, concise pleadings)
- In re Marin, 956 F.2d 339 (D.C. Cir. 1992) (district courts cannot review other federal courts’ decisions)
- Jarrell v. Tisch, 656 F. Supp. 237 (D.D.C. 1987) (pro se litigants must comply with procedural rules)