The opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
LEO WEST,
Plaintiff,
v. Civil Action No. 1:25-cv-02589 (UNA)
MIKE BOST, et al.,
Defendant.
MEMORANDUM OPINION
Before the Court is Plaintiff Leo West’s pro se Complaint, ECF No. 1, and Application for
Leave to Proceed in forma pauperis (“IFP”), ECF No. 2. The Court grants Plaintiff’s IFP
Application and, for the reasons explained below, dismisses this matter without prejudice.
West, a resident of the District of Columbia, sues several members of Congress, whom he
refers to as “Governors.” See Compl. at 1–6. The allegations are sparse and vague. Plaintiff
alleges that Defendants violated 18 U.S.C. § 1001 by making contradictory and “fraudulent
statements” regarding a “government shelter.” See id. at 7, 9. The remainder of the Complaint
consists of mere phrases, presented without context in sentence fragments or less, for example,
“access housing/veteran affairs,” “false application on government shelter,” “confusing voices,”
and “false actuzation” [sic]. See id. He demands $14 million in damages. See id. at 7.
First, pro se litigants must comply with the Federal Rules of Civil Procedure, Jarrell v.
Tisch, 656 F. Supp. 237, 239 (D.D.C. 1987), and Rule 8 requires complaints to contain “(1) a short
and plain statement of the grounds for the court’s jurisdiction [and] (2) a short and plain statement
of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a); see Ashcroft v.
Iqbal, 556 U.S. 662, 677–79 (2009). The Rule 8 standard ensures that defendants receive fair
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notice of the claim being asserted so that they can prepare a responsive answer and an adequate
defense and determine whether the doctrine of res judicata applies. Brown v. Califano, 75 F.R.D.
497, 498 (D.D.C. 1977). Here, as presented, neither the Court nor the Defendants can reasonably
be expected to identify Plaintiff’s intended claims, and the allegations fall well short of stating a
plausible claim or establishing the Court’s subject matter jurisdiction. Second, Plaintiff’s reliance
on 18 U.S.C. § 1001, a criminal statute, is misplaced because that statute does not provide a private
right of action. See Lee v. U.S. Agency for Int’l Dev., 859 F.3d 74, 78 (D.C. Cir. 2017) (per curiam).
For all these reasons, this case is dismissed without prejudice. A separate Order
accompanies this Memorandum Opinion.
DATE: November 5, 2025
CARL J. NICHOLS
United States District Judge
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