“We have never accepted ‘legal conclusions cast in the form of factual allegations’ because a complaint needs some information about the circumstances giving rise to the claims.”
How later courts described this case
- “We have never accepted ‘legal conclusions cast in the form of factual allegations’ because a complaint needs some information about the circumstances giving rise to the claims.”
Written by the judges who cited it.
The opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
MARVIN KNIGHT, )
)
Plaintiff, )
)
v. ) Civil Action No. 1: 25-cv-04126 (UNA)
)
MED-STAR WASHINGTON )
HOSPITAL CENTER, )
)
)
Defendant. )
MEMORANDUM OPINION
This matter is currently before the Court on consideration of Plaintiff’s pro se Complaint
(“Compl.”), ECF No. 1, and his Application for Leave to Proceed in forma pauperis (“IFP”), ECF
No. 2. Upon review, the Court grants Plaintiff’s IFP Application, and for the reasons explained
below, it dismisses this matter without prejudice.
Plaintiff sues MedStar Washington Hospital Center, see Compl. at 1–2, though he fails to
provide an address for either himself or the Defendant, as required, see D.C. LCvR 5.1(c)(1); see
also Mail Returned as Undeliverable, ECF No. 8. The Complaint’s allegations are vague and
spare. Plaintiff does not cite to any legal authority, and he states only that, on multiple occasions
across decades, but as recently as last year, he went to Defendant’s emergency room for care, but
received “bad treatment,” and was discriminated against. See Compl. at 3–4. He also states that
he received “multiple life saving surgeries and hospitaliz[ation] in [the] ICU[,]” though as pleaded,
it is unclear if he required this care as a result of Defendant’s alleged malpractice, or it is a non-
sequitur. See id. at 4. He contends that, due to Defendant’s alleged negligence, he has suffered
physically and has lost wages. See id. at 3–4. The specific relief sought is unspecified, though it
appears that Plaintiff may seek damages. See id.
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 here, the Complaint and its addendums fail to comply
with Rule 8(a) of the Federal Rules of Civil Procedure, which requires a pleading 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, 678–79 (2009); Ciralsky v. CIA, 355 F.3d 661, 668–71 (D.C. Cir.
2004). The Rule 8 standard ensures that defendants receive fair 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). Notably,
“[a] confused and rambling narrative of charges and conclusions . . . does not comply with the
requirements of Rule 8.” Cheeks v. Fort Myer Constr. Corp., 71 F. Supp. 3d 163, 169 (D.D.C.
2014) (citation and internal quotation marks omitted).
Plaintiff’s Complaint falls into this category. The allegations do not provide the Defendant
or the Court with adequate notice of a claim. The details and context required to state a cognizable
claim are missing––for example, how, when, or why Plaintiff was discriminated against, and by
whom, how, when, or what medical malpractice, or other negligence, he suffered, and who
allegedly committed same. The nature of his claimed damages is also vague, at best.
In sum, Plaintiff presents less than “threadbare recitals” that are “supported by mere
conclusory statements,” which is insufficient to state a claim. See Iqbal, 556 U.S. at 678. Indeed,
a complaint “must plead ‘factual matter’ that permits the court to infer ‘more than the mere
possibility of [defendant’s] misconduct.’” Atherton v. District of Columbia Office of the Mayor,
567 F.3d 672, 681–82 (D.C. Cir. 2009) (quoting Iqbal, 556 U.S. at 678–79; see Aktieselskabet AF
21. Nov.2001 v. Fame Jeans, Inc., 525 F.3d 8, 16 n.4 (D.C. Cir. 2008) (“We have never accepted
‘legal conclusions cast in the form of factual allegations’ because a complaint needs some
information about the circumstances giving rise to the claims.”) (quoting Kowal v. MCI Commc’ns
Corp., 16 F.3d 1271, 1276 (D.C. Cir. 1994)).
For these reasons, this case is dismissed without prejudice. Plaintiff’s other pending
Motions, ECF Nos. 3, 4, 5, 6, 7, are all denied as moot. A separate Order accompanies this
Memorandum Opinion.
Date: April 17, 2026 ___________/s/____________
RUDOLPH CONTRERAS
United States District Judge