949 F. Supp. 2d 50
D.D.C.2013Background
- Jones, proceeding pro se, sues the United States and non-federal actors for $75 million alleging civil-rights violations in a matter arising from investigations in Ohio.
- He amended the complaint and added several defendants; the United States, Mudra, and judges Boggs and Oliver moved to dismiss.
- The court granted all motions to dismiss under Rule 12(b)(1)–(6) for lack of jurisdiction, lack of personal jurisdiction, and immunity.
- The underlying events concern disclosures in Ohio investigations, alleged wrongful actions by Mudra/Patton, and decisions by Bryant & Stratton College and local authorities.
- Prior district court orders in Ohio restricted Jones from filing suits without leave and later plaintiffs’ other actions were dismissed or transferred.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether FTCA jurisdiction exists for monetary damages. | Jones argues FTCA waiver applies. | Defendants argue no statutory filing requirement satisfied. | FTCA prerequisite not met; no jurisdiction. |
| Whether federal judges have immunity from damages. | Jones seeks damages from judges for actions in cases. | Judicial immunity shields monetary claims. | Judicial immunity bars claims against judges. |
| Whether non-federal defendants are subject to personal jurisdiction in D.C. | Jones asserts contacts with the District. | No sufficient minimum contacts; long-arm statute inapplicable. | Lack of personal jurisdiction; claims dismissed. |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (jurisdictional rule and dismissal standards for lack of subject-matter jurisdiction)
- Akinseye v. District of Columbia, 339 F.3d 970 (D.C. Cir. 2003) (subject-matter jurisdiction requires proper basis and court may consider outside pleadings)
- Ins. Connective v. Compagnie des Bauxites de Guinee, 456 U.S. 694 (1982) (sovereign immunity and waiver principles)
- F.D.I.C. v. Meyer, 510 U.S. 471 (1994) (sovereign immunity limits against the government)
- Clark v. Library of Congress, 750 F.2d 89 (D.C. Cir. 1984) (sovereign-immunity and official actions)
- Sindram v. Suda, 986 F.2d 1459 (D.C. Cir. 1993) (absolute judicial immunity in damages actions against judges)