Endeley v. United States Department of Defense, 268 F. Supp. 3d 166

On April 6, 2017 the U.S. launched 59 Tomahawk missiles at the Al Shayrat airfield in Syria; the President notified Congress asserting inherent executive and commander‑in‑chief authority.
Four days later, pro se plaintiff Saint Jermaine Endeley sued the Department of Defense and the National Clandestine Service challenging the strike as unconstitutional under the War Powers Resolution, Article I § 8, and (as liberally construed) the AUMF; he sought an injunction preventing further military action against Syria without congressional authorization.
Plaintiff alleged injury from future and ongoing U.S. military action: his lobbying firm’s diplomatic efforts to delegitimize Assad were made harder, costing time and money; he also asserted a generalized role in “regulat[ing] administrative agencies.”
The case was transferred to the D.C. District Court; the court considered jurisdictional issues sua sponte before service and granted in forma pauperis status.
The court dismissed for lack of subject‑matter jurisdiction, concluding the complaint failed to establish Article III standing, presented unripe and potentially moot claims, and implicated nonjusticiable political‑question concerns.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing	Endeley: U.S. strikes and potential future strikes injure his firm’s lobbying efforts, costing time, labor, and money.	Defendants: (no substantive briefing); court treated jurisdictional doctrines as dispositive.	Dismissed for lack of Article III standing — alleged injuries were speculative and insufficiently concrete or imminent.
Ripeness	Endeley: prospective relief is needed to prevent further unauthorized military action.	Court: claims rest on contingent future events and are not fit for adjudication; withholding review is appropriate.	Dismissed as unripe — dispute rests on hypothetical future conduct and is not fit for judicial resolution.
Mootness / Past‑event relief	Endeley sought injunction/limitations; also challenged the April 6 strike as unlawful.	Court: past discrete strike cannot be remedied by injunction; issue likely moot absent repetition.	Past‑event claims are not redressable; the capable‑of‑repetition‑yet‑evading‑review doctrine was doubtful and unnecessary to decide.
Political‑question / Merits	Endeley: court should limit Presidential authority under the AUMF and War Powers Resolution and enjoin further action.	Court: resolving the dispute would require courts to intrude into core foreign‑policy and national‑security decisions without manageable standards.	Dismissed under the political‑question doctrine — the claim implicates foreign relations and nonjusticiable policy judgments.

Erickson v. Pardus, 551 U.S. 89 (2007) (pro se complaints construed liberally)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requirements for injury, traceability, redressability)
Raines v. Byrd, 521 U.S. 811 (1997) (heightened standing scrutiny for challenges to other branches)
City of Los Angeles v. Lyons, 461 U.S. 95 (1983) (requirements for prospective injunctive relief and imminent injury)
Abbott Laboratories v. Gardner, 387 U.S. 136 (1967) (ripeness factors: fitness and hardship)
Baker v. Carr, 369 U.S. 186 (1962) (political‑question doctrine factors)
El‑Shifa Pharmaceutical Indus. Co. v. United States, 607 F.3d 836 (D.C. Cir. 2010) (foreign‑relations and political‑question considerations)
Arpaio v. Obama, 797 F.3d 11 (D.C. Cir. 2015) (injury‑in‑fact must be actual or imminent)