Maguire v. Federal Bureau of Investigation
236 F. Supp. 3d 147
| D.D.C. | 2017Background
- Patrick Maguire (pro se) sued the FBI after submitting multiple tips through the FBI website about alleged sightings of high-profile criminals and terrorists.
- Tips referenced individuals including Joaquin "El Chapo" Guzman, Ayman Al‑Zawahiri, Joanne Chesimard, and James "Whitey" Bulger; some of those individuals were already in custody.
- Maguire styled the suit variously as a personal tort, qui tam, and whistleblower action, claiming selective enforcement and alleged mishandling/waste.
- Case was removed from D.C. Superior Court to federal court; the District Court ordered an amended complaint and considered Maguire’s subsequent filings.
- FBI moved to dismiss under Rule 12(b)(1) and 12(b)(6); the Court resolved only the jurisdictional (standing) issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing: Article III injury requirement | Maguire says FBI’s failure to act on his tips and alleged selective enforcement harmed him and warrants judicial review | FBI says plaintiff lacks Article III standing because he suffered no concrete, particularized injury traceable to the FBI | Court: No standing — plaintiff alleged no concrete or particularized injury; dismissal for lack of subject‑matter jurisdiction |
| Failure to state a claim (12(b)(6)) | Claims framed as negligence, qui tam, whistleblower and selective enforcement seeking to compel FBI to act | FBI argued claims fail as a matter of law | Court: Did not reach merits/12(b)(6) because lack of standing was dispositive |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (standing requires concrete and particularized injury)
- Summers v. Earth Island Inst., 555 U.S. 488 (standing requires a personal stake in the outcome)
- Clapper v. Amnesty Int’l USA, 568 U.S. 398 (injury must be concrete, actual or imminent, and fairly traceable)
- Valley Forge Christian College v. Americans United for Separation of Church & State, 454 U.S. 464 (traceability requirement)
- Allen v. Wright, 468 U.S. 737 (standing as case-or-controversy prerequisite)
- Monsanto Co. v. Geertson Seed Farms, 561 U.S. 139 (standing and redressability principles)
- FEC v. Akins, 524 U.S. 11 (abstract interest in law enforcement insufficient for standing)
- Coleman v. Miller, 307 U.S. 433 (noting limits on abstract injury)
- Brown v. Whole Foods Market Group, Inc., 789 F.3d 146 (courts may consider plaintiff’s opposition when resolving motions)
- Dominguez v. UAL Corp., 666 F.3d 1359 (Article III limits and separation-of-powers framing)