CRUM v. BECK, 1:21-cv-02581

Pro se plaintiff David Hall Crum, recently released from D.C. Department of Corrections custody, sued two Superior Court judges, several Assistant United States Attorneys, and a private attorney alleging misconduct arising from unspecified Superior Court criminal proceedings.
Crum alleges that after designation to the D.C. Central Detention Facility his medical needs were ignored because CDF lacked his supporting medical records; he also asserts slander and claims defendants caused his homelessness and seeks money damages.
Plaintiff filed an application to proceed in forma pauperis, and the court reviewed the complaint on initial screening.
The complaint failed to provide the name and full residence or official address for each defendant in the caption as required by Local Civil Rule 5.1(c)(1).
The court found the pleadings to be vague and disorganized, failing to give defendants fair notice of the claims as required by Federal Rule of Civil Procedure 8(a).
The court concluded that judges (and certain prosecutorial functions) are entitled to absolute immunity for judicial/quasi-judicial acts and dismissed the case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Compliance with Local Rule 5.1(c)(1) (caption addresses)	Crum filed pro se and proceeded IFP but did not list full addresses for each defendant in the caption.	Defendants rely on procedural rules requiring proper captioning and addresses.	Court held plaintiff failed to comply with LCvR 5.1(c)(1); this is a basis for dismissal.
Judicial/prosecutorial immunity for damages	Crum seeks money damages for alleged judicial/prosecutorial actions related to his criminal proceedings.	Judges and prosecutors are absolutely immune for actions within their judicial or quasi‑judicial roles.	Court held judges (and prosecutorial acts tied to the judicial phase) are immune from money damages; claims against judges/prosecutors barred.
Sufficiency of pleading under Rule 8	Crum alleges constitutional violations (medical neglect), slander, and homelessness but provides few factual specifics or clear legal theories.	Defendants contend the complaint must give short, plain statements showing entitlement to relief so they can defend and assess res judicata.	Court held the complaint is an untidy, vague assortment of claims that fails Rule 8(a) and therefore warrants dismissal.

Mireles v. Waco, 502 U.S. 9 (1991) (establishes judicial immunity from damages for judicial acts)
Stump v. Sparkman, 435 U.S. 349 (1978) (broad construction of judge's jurisdiction for immunity purposes)
Sindram v. Suda, 986 F.2d 1459 (D.C. Cir. 1993) (reaffirms absolute judicial immunity except when acting in absence of all jurisdiction)
Gray v. Bell, 712 F.2d 490 (D.C. Cir. 1983) (absolute prosecutorial immunity for activities intimately associated with judicial phase)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standards require more than conclusory allegations)
Ciralsky v. CIA, 355 F.3d 661 (D.C. Cir. 2004) (Rule 8 ensures fair notice of claims for defendants)
Jiggetts v. D.C., 319 F.R.D. 408 (D.D.C. 2017) (complaints that are untidy and conclusory fail Rule 8)