holding that threadbare recitals and conclusory statements are insufficient to state a claim
How later courts described this case
- holding that threadbare recitals and conclusory statements are insufficient to state a claim
- “bare assertions” of a claim are “not entitled to be assumed true.”
Written by the judges who cited it.
The opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
LIAM ALEXANDER, )
)
Plaintiff, )
)
v. ) Civil Action No. 1:26-cv-00836 (UNA)
)
AMTRAK, et al., )
)
Defendants. )
MEMORANDUM OPINION
This matter is before the Court on its initial review of Plaintiff’s pro se Complaint
(“Compl.”), ECF No. 1, and Application for Leave to Proceed in forma pauperis (“IFP”). The
Court grants Plaintiff’s IFP Application, and for the reasons discussed below, it dismisses the
Complaint, and this matter, without prejudice.
Plaintiff provides an address in Albany, New York, but also claims that he is a resident of
the District of Columbia. Compare Compl. at 1, with id. at 3. He sues Amtrak and Amtrak Police.
See id. at 2. The Complaint is vague, at best. Plaintiff broadly alleges that Defendants engaged in
fraud, “breached [an] agreement,” “violated terms and conditions,” and “made false statements to
arrest” him. See id. at 3–4. He also alleges that he has “suffered near fatal medical complications.”
See id. at 4. He demands $50 million in damages. See id.
Federal Rule 8(a) 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, 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 . . . 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).
The instant Complaint falls squarely within this category. Plaintiff does not cite to any
legal authority, nor does he provide any context or necessary details to support any intended claim;
for example, how, when, or where any of the alleged wrongdoing occurred, or who committed the
alleged wrongdoing, and in what manner it harmed him. As pleaded, Plaintiff has stated only bare
conclusions that fail to provide the Defendants or the Court with adequate notice of a claim. See
Iqbal, 556 U.S. at 678 (holding that threadbare recitals and conclusory statements are insufficient
to state a claim); see also id. at 682 (“bare assertions” of a claim are “not entitled to be assumed
true.”).
Accordingly, this matter is dismissed without prejudice. A separate Order accompanies
this Memorandum Opinion.
DATE: June 1, 2026 /s/ CHRISTOPHER R. COOPER
United States District Judge