The opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
MATTHEW ROBERT ELMORE, )
)
Plaintiff, )
)
v. ) Civil Action No. 25-2251 (UNA)
)
BANK OF AMERICA, )
)
Defendant. )
MEMORANDUM OPINION
This matter is before the Court on review of plaintiff’s application to proceed in forma
pauperis and pro se civil complaint. The Court GRANTS the application and, for the reasons
stated below, DISMISSES the complaint and this civil action without prejudice.
The Court has reviewed plaintiff’s complaint, keeping in mind that complaints filed by pro
se litigants are held to less stringent standards than are applied to formal pleadings drafted by
lawyers. See Haines v. Kerner, 404 U.S. 519, 520 (1972). Even pro se litigants must comply with
the Federal Rules of Civil Procedure. Jarrell v. Tisch, 656 F. Supp. 237, 239 (D.D.C. 1987). Rule
8(a) of the Federal Rules of Civil Procedure requires that a complaint contain a short and plain
statement of the grounds upon which the Court’s jurisdiction depends, a short and plain statement
of the claim showing that the pleader is entitled to relief, and a demand for judgment for the relief
the pleader seeks. Fed. R. Civ. P. 8(a). The purpose of the minimum standard of Rule 8 is to give
fair notice to the defendants of the claim being asserted such that they might 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).
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Plaintiff demands that Bank of America produce “all bank records since 1980 in all of
[plaintiff’s] names.” Compl. at 3; see id. at 4. Although plaintiff invokes federal question
jurisdiction, see id. at 3, it is unclear that a demand for records purportedly maintained by a
corporation amounts to a “civil action[] arising under the Constitution, laws, or treaties of the
United States,” 28 U.S.C. § 1331. Even if this were a matter over which this Court has
jurisdiction, the complaint fails to allege sufficient facts to put Bank of America on notice of
plaintiff’s claim, particularly because the complaint does not identify any other names by which
plaintiff is or was known.
As drafted, the complaint does not comply with Rule 8, and it will be dismissed. An
Order consistent with this Memorandum Opinion is issued separately.
DATE: January 2, 2026 /s/
ANA C. REYES
United States District Judge
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