Arnold v. White House
Opinion
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
In June 2025, the court sua sponte dismissed Plaintiff Marie Encar Arnold’s pro se
complaint for failure to comply with Federal Rule of Civil Procedure 8(a), but the court permitted
Ms. Arnold to file an amended complaint within thirty days. ECF Nos. 3, 4. Ms. Arnold timely
filed an amended complaint, ECF No. 6, but the court will dismiss it because it suffers from the
same Rule 8(a) defects as her initial complaint.
I. FACTUAL BACKGROUND
In May 2025, Ms. Arnold filed a complaint against the White House, the Executive Branch,
and President Donald J. Trump in his official capacity, alleging violations of the Federal
Arbitration Act,
9 U.S.C. §§ 1et 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. § 2671et seq. See generally
ECF No. 1-1. In June 2025, the court sua sponte dismissed Ms. Arnold’s complaint without
prejudice under Federal Rule of Civil Procedure 8(a) and granted her leave to file an amended
1 complaint that complied with the Federal Rules of Civil Procedure within thirty days. ECF Nos. 3,
4. Ms. Arnold thereafter filed an amended complaint. ECF No. 6.
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,
355 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 again sua sponte dismiss Ms. Arnold’s amended complaint because it fails
to meet Rule 8’s pleading standard for largely the same reasons stated in the court’s earlier opinion.
2 ECF No. 3, at 1-2. The court granted Ms. Arnold leave to amend her complaint so that she could
“cure[] the existing deficiencies” in her original complaint, id. at 1, but her amended complaint is
substantially similar to her original complaint, compare ECF No. 1, with ECF No. 6. The most
salient difference between the two is that her amended complaint includes additional monetary
“proposals,” such as “$3 Billion [to] U.S. Defense” and “$1 Billion to NASA and out contracts
Space X, Falcon 9.” ECF No. 6 ¶¶ 3-8. But the court still 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). At this point,
the court does not find that further opportunities to amend will save Ms. Arnold’s claims.
Accordingly, the court will dismiss her complaint with prejudice. See
id.(explaining that a court
may dismiss with prejudice when the amended complaint “merely recycles” the original
complaint).
III. CONCLUSION
For the foregoing reasons, Plaintiff’s amended complaint, ECF No. 6, and this matter are
dismissed with prejudice. A contemporaneous order will issue.
LOREN L. ALIKHAN United States District Judge Date: July 28, 2025
3
Reference
- Status
- Published