State of Washington v. Pigott
2:25-mc-00019
W.D. Wash.May 16, 2025Background
- Joseph Stanley Pigott, proceeding pro se under the alias King Abdul Mumin El, sought leave to proceed in forma pauperis (IFP) and attempted to remove a criminal case against him in King County Superior Court to federal court.
- Pigott filed a notice of removal and complaint alleging false imprisonment by various judicial and prosecutorial officials involved in his state criminal proceedings.
- The matter came before the U.S. District Court for the Western District of Washington.
- The court undertook mandatory screening of Pigott’s filings under 28 U.S.C. § 1915(e)(2)(B) due to his IFP application.
- Pigott’s pleadings were assessed for sufficiency under Federal Rule of Civil Procedure 8, which requires a short and plain statement of the claim and the relief sought.
- The court previously explained to Pigott that he did not meet the requirements for federal removal of his state criminal case and reiterated these deficiencies in this action.
Issues
| Issue | Pigott's Argument | State's Argument | Held |
|---|---|---|---|
| Whether pro se petition sufficiently states a claim | Claims false imprisonment, removal to federal court warranted | Removal unjustified, fails to state a federal claim | Dismissed with prejudice; no claim stated |
| Sufficiency of complaint under FRCP 8 | Seeks relief from state action due to alleged violations | Complaint lacks clarity, factual or legal basis | Pleading fails Rule 8 requirements |
| Eligibility to remove state criminal case to federal | Entitled to remove under 28 U.S.C. § 1455 | Removal requirements unmet | Removal improper |
| IFP status | Requests to proceed in forma pauperis | Motion moot due to dismissal | Motion stricken as moot |
Key Cases Cited
- Lopez v. Smith, 203 F.3d 1122 (9th Cir. 2000) (establishing that frivolous or meritless complaints can be dismissed without leave to amend)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (clarifying that complaints must assert more than conclusory statements to survive dismissal)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (outlining pleading standards under Rule 8)
- Hebbe v. Pliler, 627 F.3d 338 (9th Cir. 2010) (holding that pro se complaints are construed liberally)