“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.”
How later courts described this case
- “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.”
Written by the judges who cited it.
The opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
CYNTHIA WILLIAMS,
Plaintiff,
Civil Action No. 23-03028 (AHA)
v.
DREYFUSS MANAGEMENT,
Defendant.
Memorandum Opinion
Cynthia Williams appears to sue her property manager, Dreyfuss Management, based on
allegations of fraud and abuse. Because, after multiple opportunities, Williams has not provided
sufficient notice of her claims against Dreyfuss Management, as Federal Rule of Civil Procedure
8 requires, the court dismisses the case.
It appears that Williams rents an apartment in a building Dreyfuss Management manages.
See ECF No. 8 at 1. In her pleadings, Williams describes herself as a retired senior citizen who has
been “abused by” Dreyfuss Management. ECF No. 12. She refers to “fraudulent contracts,”
including a lease she believes is “fake.” Id. Her pleadings also allege that Dreyfuss Management’s
employees have beaten her, held her hostage, stalked her, broken into her apartment, and left the
apartment a mess. Id.
Williams filed her original complaint in October 2023. After over a year without action,
this court directed Williams to notify the court whether she intended to continue with the case and,
because Williams is proceeding in forma pauperis, ordered the U.S. Marshals Service to effect
service. 1 In June 2025, Dreyfuss Management moved to dismiss or for a more definite statement.
ECF No. 8. The court granted the motion for a more definite statement and allowed Williams to
file an amended complaint that complies with the federal rules, directing her to resources for pro
se litigants and cautioning her that failure to comply with the applicable rules may lead to dismissal
of her suit. Williams responded by filing a “motion to continue,” which was illegible and difficult
to parse. See ECF No. 11. The court construed the motion as a motion for an extension of time to
file an amended complaint and granted it. Williams then filed another pleading styled as a “motion
to continue” that was typewritten and legible. See ECF No. 12. The court construes this submission
as a supplemental pleading. In it, in addition to the allegations above, Williams asserts Dreyfuss
Management has violated her rights under the Thirteenth and Fourteenth Amendments to the U.S.
Constitution. Id. She claims she has suffered “emotional and physical abuse” and asks for $20
billion in damages. See id.
Dreyfuss Management has filed a response, arguing that the action should be dismissed for
failure to file a complaint that provides sufficient notice of her claims, as required by Federal Rule
of Civil Procedure 8. ECF No. 13 at 5. The court agrees.
A complaint must contain “a short and plain statement of the claim showing that the pleader
is entitled to relief.” Fed. R. Civ. P. 8(a)(2). This “does not require ‘detailed factual allegations,’
but it demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.”
Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544,
555 (2007)). The rule ensures that the defendant has “notice of what the claim is and the grounds
upon which it rests.” Twombly, 550 U.S. at 555 (cleaned up) (quoting Conley v. Gibson, 355 U.S.
1
This case was initially assigned to the Honorable Reggie B. Walton and was reassigned to the
Honorable Amir H. Ali on November 27, 2024.
2
41, 47 (1957)). A court may dismiss a complaint that fails to adhere to these requirements either
upon a motion or on its own accord. See Fed. R. Civ. P. 41(b); see also Ciralsky v. CIA, 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 acts with extra care in reviewing a pro se complaint, construing the allegations
liberally and “in light of all filings.” Ho v. Garland, 106 F.4th 47, 50 (D.C. Cir. 2024) (quotation
marks omitted) (quoting Brown v. Whole Foods Mkt. Grp., Inc., 789 F.3d 146, 152 (D.C. Cir.
2015)). However, pro se litigants must still comply with the applicable rules. See Jarrell v. Tisch,
656 F. Supp. 237, 239–40 (D.D.C. 1987).
Here, Williams’ pleadings, including her original complaint and subsequent submissions,
do not meet Rule 8’s minimal requirement to provide notice of what her claims are. After multiple
opportunities, Williams has not alleged facts stating when, where and how Dreyfuss Management
wronged her, let alone articulated a plausible basis for the extraordinary damages sought.
The court accordingly dismisses this action without prejudice for failure to give the notice
that Rule 8 requires. A separate order accompanies this memorandum opinion.
AMIR H. ALI
United States District Judge
Date: November 4, 2025
3