Zhou v. Herring, Civil Action No. 2017-2155

Plaintiff Huixuan Zhou, unhappy with outcomes of a Virginia custody dispute, has repeatedly sued parties involved in that litigation and related proceedings.
In this action Zhou sued Virginia officials including Attorney General Mark Herring and several deputy/assistant attorneys general, alleging bribery, aiding an alleged kidnapping of her daughter, and other misconduct.
The Complaint is 35 pages but largely recounts alleged misconduct by numerous non-defendant actors from the Virginia litigation; allegations against named defendants are vague and legally undeveloped.
The Complaint fails to plead a short, plain statement giving defendants fair notice of claims under Fed. R. Civ. P. 8(a); many allegations are conclusory and undecipherable.
The alleged events occurred in Virginia and bear no apparent connection to the District of Columbia; venue therefore is improper in this district.
The court dismissed the case without prejudice for failure to meet Rule 8(a) and because the action lacks any connection to the District of Columbia (rather than transferring to Virginia).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of pleadings under Rule 8(a)	Zhou alleges bribery, kidnapping assistance, and misconduct by named officials and seeks relief	Defendants (implicitly) claim complaint fails to give fair notice and lacks factual support	Court: Complaint fails Rule 8(a); allegations are conclusory/undecipherable and dismissal is appropriate
Venue in D.C. under 28 U.S.C. § 1391	Zhou filed in D.C.; alleges misconduct by Virginia officials	Defendants (implicitly) contend events occurred in Virginia so D.C. lacks venue	Court: No connection to D.C.; venue improper; court dismisses rather than transfers
Whether to dismiss or transfer under § 1406(a)	Zhou did not establish clear basis to keep action in D.C.	Defendants would favor dismissal or transfer to appropriate district	Court: Exercises discretion to dismiss without prejudice rather than transfer
Treatment of pro se filings	Zhou entitled to lenient reading but still must follow rules	Defendants rely on Rule 8(a) and venue statutes to challenge pleading	Court: Applies pro se leniency but enforces Rule 8(a); dismissal warranted

Haines v. Kerner, 404 U.S. 519 (1972) (pro se complaints are held to less stringent standards)
Jarrell v. Tisch, 656 F. Supp. 237 (D.D.C. 1987) (pro se litigants must still comply with the Federal Rules of Civil Procedure)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must contain enough factual matter to suggest liability; Rule 8 requires fair notice)