Opinion

Jackson v. Bessent

Court
District Court, District of Columbia
Filed
May 8, 2026
Status
Published
On the bench
Judge Trevor N. McFadden
Cited by
0 cases
Authority
More cited than 40.5%

noting courts’ obligation to consider all pro se filings together

How later courts described this case

  • noting courts’ obligation to consider all pro se filings together

Written by the judges who cited it.

The opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

FRED J. JACKSON, JR.,

Plaintiff,

v. Case No. 1:25-cv-3551 (TNM)

SCOTT BESSENT, Secretary of the

Treasury,

Defendant.

MEMORANDUM OPINION

Fred Jackson, proceeding pro se, sues the Secretary of the Treasury for employment

discrimination. Compl., ECF No. 1. The Secretary moves to dismiss his Complaint. Def.’s

Mot., ECF No. 5. Because Jackson falls short of minimum pleading standards set out by Rule

8(a) of the Federal Rules of Civil Procedure, the Court will grant the Secretary’s motion and

dismiss Jackson’s Complaint.

Rule 8(a) requires that complaints contain “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 purpose

of the Rule 8 standard is to provide fair notice to the defendants of the claim being asserted so

that they can prepare a responsive answer, prepare 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).

In applying this standard to pro se litigants like Jackson, the Court must liberally construe

the pleadings, recognizing that pro se pleadings and are held to a less stringent standard than

formal pleadings drafted by lawyers. Erickson v. Pardus, 551 U.S. 89, 94 (2007). Yet pro se

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litigants must still comply with the Federal Rules of Civil Procedure. See Jarrell v. Tisch, 656 F.

Supp. 237, 239 (D.D.C. 1987).

Jackson’s Complaint does not meet minimum pleading requirements. In few sentences,

he alleges that the Treasury Department offered him a job but rescinded the offer part way

through its background check on Jackson. Compl. at 5. Before this rescission, Jackson “raised

concerns” about that investigation and “reported possible fraud, waste, and abuse” and requested

to undergo “counseling” with the Equal Employment Opportunity Commission. Id. Jackson

provides no other factual detail. He seeks relief “that would have been afforded” had the

Treasury not engaged in “discriminatory conduct,” including service credit, back-pay, sick

accrual, and other damages. Id. at 6. His Complaint ends there. In his response to the

Secretary’s motion, Jackson clarifies that he pursues a race discrimination claim. Pl.’s Response

at 5, ECF No. 8; see Richardson v. United States, 193 F.3d 545, 548 (D.C. Cir. 1999) (noting

courts’ obligation to consider all pro se filings together).

Considering Jackson’s scant pleadings altogether, he has failed to make out a race

discrimination claim, or any other discernable claim. Nowhere in Jackson’s factual allegations

does he say anything about racial discrimination. Compl. at 5. He mentions only that he “raised

concerns” about “possible fraud, waste, and abuse” and sought “counseling.” Id. If revoking a

job offer in response to those actions amounted to a race-based decision, Jackson has said

nothing to suggest that race played a role. In fact, he alleges so little about race-based treatment

that the Secretary read Jackson’s Complaint as possibly bringing a whistleblower claim, see

Def.’s Mot. at 7, a possibility that Jackson’s explicitly denounced in his Response brief, Pl.’s

response at 5 (“Defendant mischaracterizes Plaintiff’s claims as whistleblower claims.”). As the

Secretary’s confusion confirms, Jackson’s allegations provide the Secretary insufficient notice of

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the supposed discrimination claim against it. Brown, 75 F.R.D. at 498; Fed. R. Civ. P. 8(a).

Jackson has identified no other feasible claims, and the Court sees none. 1

The Court will accordingly dismiss his Complaint without prejudice. An order consistent

with this Memorandum Opinion will issue today.

2026.05.08

14:16:57 -04'00'

Dated: May 8, 2026 TREVOR N. McFADDEN, U.S.D.J.

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Jackson asks the Court to grant him leave to amend his Complaint should it require additional

factual detail. Because the Court will dismiss the Complaint without prejudice, the proper course

for Jackson is to refile a Complaint that complies with the Federal Rules of Civil Procedure

should he still seek relief.

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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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