CHEEKS v. POWERBALL
1:24-cv-02724
D.D.C.Jun 6, 2025Background
- Plaintiff John Conrad Cheeks filed a pro se lawsuit against the Florida Lottery (initially named as "Powerball Lottery") claiming entitlement to a $320,600,000 Powerball prize based on numbers displayed on the DC Lottery’s website.
- Cheeks purchased his ticket from a DC retailer and alleged that numbers issued by the Florida Lottery matched his ticket.
- Cheeks attempted service via USPS Certified Mail and moved for default judgment after the Florida Lottery sought an extension to respond.
- The Florida Lottery filed a motion to dismiss for lack of personal jurisdiction, insufficient process, insufficient service, and failure to state a claim.
- Evidence submitted by Cheeks included a declaration from the DC Office of Lottery and Gaming, stating the posted numbers were “test numbers” accidentally displayed, not the actual winning numbers.
- The Court focused its analysis on whether it could exercise personal jurisdiction over the Florida Lottery.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal Jurisdiction | Florida Lottery has sufficient contact with DC | No relevant conduct or business activity by Florida Lottery in DC | No personal jurisdiction; case dismissed |
| Service of Process | Mailed summons/complaint should suffice | Service was improper under rules for serving state agencies | Not addressed due to lack of jurisdiction |
| Failure to State a Claim | Entitled to winnings due to matching website numbers | No contractual/statutory obligation breached; numbers posted were test numbers | Not reached |
| Motion for Default Judgment | Defendant failed to timely respond | Defendant received court-approved extension | Plaintiff's motion denied; extension was granted |
Key Cases Cited
- Erickson v. Pardus, 551 U.S. 89 (2007) (standards for construing pro se complaints)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard for factual matter in complaints)
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (2011) (test for general jurisdiction)
- Daimler AG v. Bauman, 571 U.S. 117 (2014) (limits on general jurisdiction for entities)
- Walden v. Fiore, 571 U.S. 277 (2014) (minimum contacts analysis for specific jurisdiction)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (purposeful availment and specific jurisdiction)
- Int’l Shoe Co. v. Washington, 326 U.S. 310 (1945) (due process and minimum contacts standard for personal jurisdiction)