Doss v. U.S. Probation Office
Civil Action No. 2017-0093
| D.D.C. | May 12, 2017Background
- Pro se plaintiff Angel Pastor Doss sued the U.S. Probation Office, four federal judges, nine Senators, and Speaker Paul Ryan, seeking money damages and an ambassadorship.
- Complaint contained scattered allegations about a 1978 automobile accident, a 1985 arrest, and generalized claims that legislative, judicial, and government employees fragmented his life.
- Pleading was titled as a conspiracy claim but did not identify a coherent legal theory or connect factual allegations to a cause of action.
- Plaintiff requested punitive damages ($50 million) and non-monetary relief (an ambassadorship), but gave no factual or legal basis tying defendants to actionable wrongdoing.
- The Court reviewed the complaint sua sponte for dismissal under Federal Rules of Civil Procedure 8(a) and 12(b)(6) because the pleading failed to state a plausible claim and did not give defendants adequate notice of the alleged unlawful acts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the complaint satisfies Rule 8(a)’s short and plain statement requirement | Doss alleges a broad conspiracy and harm from government actors but does not plead a clear claim | Defendants (by implication) lack notice because the pleading is vague and disconnected | Complaint fails Rule 8(a); dismissal warranted |
| Whether the complaint states a plausible claim under Rule 12(b)(6) | Doss seeks damages and relief for alleged conspiratorial conduct | Defendants (by implication) cannot be liable because no factual basis or legal theory is pleaded | Complaint does not plead facts permitting a reasonable inference of liability; dismissal warranted |
| Whether pro se status requires leniency that would save the complaint | Doss is pro se and entitled to liberal construction of pleadings | The Court may dismiss pro se complaints that are patently baseless or lack any legal or factual basis | Pro se status does not excuse failure to follow the Rules; liberal reading insufficient to salvage this complaint |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading must state a plausible claim allowing reasonable inference of liability)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for federal pleadings)
- Scheuer v. Rhodes, 416 U.S. 232 (Rule 12(b)(6) tests sufficiency of complaint)
- Sinclair v. Kleindienst, 711 F.2d 291 (complaint must give adequate notice of alleged unlawful acts)
- Bauer v. Marmara, 942 F. Supp. 2d 31 (court may dismiss sua sponte when failure to state a claim is patent)
- Erickson v. Pardus, 551 U.S. 89 (pro se pleadings entitled to liberal construction)
- Jarrell v. Tisch, 656 F. Supp. 237 (pro se status does not permit ignoring procedural rules)
- Perry v. Discover Bank, 514 F. Supp. 2d 94 (dismissal appropriate when no factual or legal basis for alleged wrongdoing)
- Baker v. Director, U.S. Parole Comm’n, 916 F.2d 725 (standard for sua sponte dismissal when plaintiff cannot prevail on alleged facts)