Arnold v. White House
Arnold
Court
District Court, District of Columbia
Decided
June 17, 2025
Jurisdiction
FD
Importance
42%
Practice Areas
Case Summary
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARIE ENCAR ARNOLD, Plaintiff, v. Civil Action No. 25 - 1695 (LLA) WHITE HOUSE, et al., Defendants. MEMORANDUM OPINION Plaintiff Marie Encar Arnold, proceeding pro se, filed a civil complaint against the White House, the Executive Branch, and President Donald J. Trump in his official capacity. ECF No. 1. For the reasons explained below, the court will dismiss the complaint and allow Ms. Arnold to file an amended complaint that cures the existing deficiencies within thirty days. I. FACTUAL BACKGROUND In May 2025, Ms. Arnold filed a complaint against Defendants alleging violations of the Federal Arbitration Act, 9 U.S.C. §§ 1 et seq., and seeking to compel Defendants to engage in a settlement conference, see generally ECF No. 1. Her claims appear to relate to an administrative claim for $10 billion that she filed under the Federal Tort Claims Act, 28 U.S.C. § 2671 et seq. See generally ECF No. 1-1. II. DISCUSSION Complaints by pro se litigants are held to “less stringent standards than formal pleadings drafted by lawyers.” Haines v. Kerner, 404 U.S. 519, 520 (1972). Even a pro se litigant, however, must comply with the Federal Rules of Civil Procedure. Jarrell v. Tisch, 656 F. Supp. 237, 239 (D.D.C. 1987). Rule 8(a) requires that a complaint include: (1) “a short and plain statement of the grounds for the court’s jurisdiction”; (2) “a short and plain statement of the claim showing that the pleader is entitled to relief”; and (3) “a demand for the relief sought.” Fed. R. Civ. P. 8(a)(1)-(3). The rule ensures that defendants have “notice of what the . . . claim is and the grounds upon which it rests.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 545 (2007). A complaint that is “excessively long, rambling, disjointed, incoherent, or full of irrelevant and confusing material” or one that “contains an untidy assortment of claims that are neither plainly or concisely stated, nor meaningfully distinguished from bold conclusions, sharp harangues and personal comments” does not meet Rule 8’s pleading standard. Jiggetts v. District of Columbia, 319 F.R.D. 408, 413 (D.D.C. 2017), aff’d sub nom. Cooper v. District of Columbia, No. 17-7021, 2017 WL 5664737 (D.C. Cir. Nov. 1, 2017) (quoting T.M. v. District of Columbia, 961 F. Supp. 2d 169, 174 (D.D.C. 2013)). A court may dismiss a complaint that fails to adhere to the requirements of Rule 8 either upon a motion or sua sponte. See Fed. R. Civ. P. 41(b); see also Ciralsky v. Cent. Intel. Agency, 344 F.3d 661, 669 (D.C. Cir. 2004) (“Rule 41(b) authorizes the court to dismiss either a claim or an action because of the plaintiff’s failure to comply with the Federal Rules . . . .”). The court will sua sponte dismiss Ms. Arnold’s complaint because it fails to meet Rule 8’s pleading standard. Specifically, the court cannot discern the substance of Ms. Arnold’s claims or determine whether, if true, her allegations would entitle her to relief. See Brown v. Wash. Metro. Area Transit Auth., 164 F. Supp. 3d 33, 35 (D.D.C. 2016). The court will, however, grant Ms. Arnold leave to file an amended complaint that complies with Rule 8 within thirty days. Id. III. CONCLUSION For the foregoing reasons, the court will sua sponte dismiss Ms. Arnold’s complaint but grant Ms. Arnold leave to file an amended complaint within thirty days. 2 LOREN L. ALIKHAN United States District Judge Date: June 17, 2025 3
Case Details
Case Details
Legal case information
Status
Decided
Date Decided
June 17, 2025
Jurisdiction
FD
Court Type
district
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Case Summary
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Case Overview
Case Name: Arnold v. White House
Citation: Unknown
Court: District Court, District of Columbia
Date: June 17, 2025
Jurisdiction: Federal District (FD)
In this case, Marie Encar Arnold, representing herself, filed a civil complaint against the White House, the Executive Branch, and President Donald J. Trump in his official capacity. The complaint was filed under Civil Action No. 25 - 1695 (LLA).
Key Legal Issues
- Allegations of violations under the Federal Arbitration Act (9 U.S.C. §§ 1 et seq.)
- Request to compel the defendants to engage in a settlement conference
- Relation to an administrative claim for $10 billion filed under the Federal Tort Claims Act (28 U.S.C. § 2671 et seq.)
Court's Decision
The court decided to dismiss the complaint due to its failure to meet the pleading standards set forth in Federal Rule of Civil Procedure 8. However, it granted Ms. Arnold leave to file an amended complaint within thirty days to address the deficiencies.
Legal Reasoning
The court emphasized that while pro se litigants are held to less stringent standards, they must still comply with the Federal Rules of Civil Procedure. Specifically, Rule 8(a) requires:
- A short and plain statement of the grounds for the court’s jurisdiction
- A short and plain statement of the claim showing entitlement to relief
- A demand for the relief sought
The court noted that Ms. Arnold's complaint was excessively long, disjointed, and failed to provide clarity on the claims, which hindered the defendants' ability to respond adequately. The court referenced Haines v. Kerner and Jarrell v. Tisch to underscore the necessity of adhering to procedural standards.
Key Holdings
- The court dismissed Ms. Arnold's complaint for failing to meet the Rule 8 pleading standard.
- The court allowed Ms. Arnold to amend her complaint to correct the deficiencies within thirty days.
Precedents and Citations
- Haines v. Kerner, 404 U.S. 519 (1972)
- Jarrell v. Tisch, 656 F. Supp. 237 (D.D.C. 1987)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007)
- Jiggetts v. District of Columbia, 319 F.R.D. 408 (D.D.C. 2017)
Practical Implications
This case highlights the importance of adhering to procedural rules in civil litigation, particularly for pro se litigants. The court's decision underscores that:
- Even self-represented individuals must provide clear and concise claims.
- Failure to comply with procedural standards can lead to dismissal, even if the plaintiff is acting without legal representation.
- The opportunity to amend a complaint provides a crucial second chance for plaintiffs to articulate their claims effectively.
In conclusion, Arnold v. White House serves as a reminder of the necessity for clarity and adherence to legal standards in civil complaints, particularly when engaging with high-profile defendants such as the Executive Branch.
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Case Details
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Status
Decided
Date Decided
June 17, 2025
Jurisdiction
FD
Court Type
district
Legal Significance
Case importance metrics
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Additional information
Quick Actions
Case management tools