The opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
JAMEL VICTOR THORNTON,
Plaintiff,
Civil Action No. 25-00178 (AHA)
v.
JOSEPH R. BIDEN, JR.,
Defendant.
Memorandum Opinion
Jamel Thornton sues former President Joseph R. Biden, alleging President Biden failed to
disclose information about his health and that health issues compromised his ability to perform his
duties as President. Thornton claims this conduct violates multiple constitutional provisions, and
he seeks a “judicial determination of the President’s fitness for office, an order requiring the
disclosure of relevant medical and cognitive evaluations necessary to assess the President’s
capacity to execute his constitutional responsibilities, and a writ of mandamus directing” certain
executive branch officials “to fulfill their constitutional obligations under the Twenty-Fifth
Amendment.” ECF No. 1 ¶ 10. President Biden moves to dismiss, arguing, among other things,
that Thornton does not have standing. The court agrees and grants the motion.
When considering a motion to dismiss for lack of subject matter jurisdiction, the court must
“assume the truth of all material factual allegations in the complaint and ‘construe the complaint
liberally, granting plaintiff the benefit of all inferences that can be derived from the facts alleged.’”
Am. Nat. Ins. Co. v. F.D.I.C., 642 F.3d 1137, 1139 (D.C. Cir. 2011) (quoting Thomas v. Principi,
394 F.3d 970, 972 (D.C. Cir. 2005)). Because Thornton is proceeding pro se, the court is careful
to give extra leeway, evaluating the complaint “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)). To have standing, a plaintiff must plausibly allege they have
“suffered, or will suffer, an injury that is ‘concrete, particularized, and actual or imminent; fairly
traceable to the challenged action; and redressable by a favorable ruling.’” Murthy v. Missouri,
603 U.S. 43, 57 (2024) (quoting Clapper v. Amnesty Int’l USA, 568 U.S. 398, 409 (2013)). If a
plaintiff fails to establish standing, the court “lack[s] jurisdiction to reach the merits.” Id. at 56.
Thornton does not have standing because he does not allege concrete and particularized
injury. The complaint alleges President Biden’s “refusal to release critical health information
undermines public trust, creates uncertainty about his capacity to govern, and poses systemic risks
to state sovereignty, individual rights, and national stability.” ECF No. 1 ¶ 5. The complaint also
alleges various actions and policy decisions by President Biden that Thornton believes evince
cognitive and physical impairments and a lack of forthrightness about such alleged impairments.
Id. ¶¶ 23–61. But Thornton fails to allege any particular harm to him. Rather, he alleges “precisely
the kind of undifferentiated, generalized grievance[s] about the conduct of government that
[courts] have refused to countenance in the past.” Lance v. Coffman, 549 U.S. 437, 442 (2007).
Because Thornton has not adequately alleged injury, he does not have standing.
Accordingly, President Biden’s motion to dismiss is granted, and this action is dismissed
without prejudice.
A separate order accompanies this memorandum opinion.
AMIR H. ALI
United States District Judge
Date: January 22, 2026
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