Brodzki v. Federal Bureau of Investigation
CourtDistrict Court, District of Columbia
Date FiledSeptember 17, 2026
DocketCivil Action No. 2026-2854
JudgeJudge Timothy J. Kelly
StatusPublished
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Full Opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
ANTHONY BRODZKI, )
Plaintiff,
V. Civil Action No. 26-2854 (UNA)
FEDERAL BUREAU OF
INVESTIGATION, )
Defendant.
MEMORANDUM
This matter is before the Court on its initial review of Plaintiffs application for leave to
proceed in forma pauperis (ECF No. 2) and pro se complaint (ECF No. 1). The Court grants the
application and dismisses the complaint and the case without prejudice.
The Federal Rules of Civil Procedure require that a complaint contain “‘a short and plain
statement of the claim showing that the pleader is entitled to relief,’ in order to ‘give the defendant
fair notice of what the . . . claim is and the grounds upon which it rests[.]’” Bell Atl. Corp. v.
Twombly, 550 U.S. 544, 555 (2007) (quoting Conley v. Gibson, 355 U.S. 41, 47 (1957)). Further,
a complaint must “contain sufficient factual matter, accepted as true, to ‘state a claim to relief that
is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Zwombly, 550 U.S.
at 570). A claim is facially plausible “when the plaintiff pleads factual content that allows the
court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id.
(quoting Zwombly, 550 U.S. at 556). Although a pro se complaint is “held to less stringent
standards than formal pleadings drafted by lawyers,” Erickson v. Pardus, 551 U.S. 89, 94 (2007)
(per curiam) (internal quotation marks and citation omitted), it “must plead ‘factual matter’ that
permits the court to infer ‘more than the mere possibility of misconduct,’” Atherton v. District of
Columbia Office of the Mayor, 567 F.3d 672, 681-82 (D.C. Cir. 2009) (quoting /gbal, 556 U.S. at
678-79). As drafted, the complaint fails to meet these goals.
As best the Court can tell, Plaintiff attempts to bring claims under criminal statutes, see
Compl. (ECF No. lat 1) (citing 18 U.S.C. §§ 241, 242, 2340), pursuant to which there is no private
right of action. See, e.g., Wilson v. U.S. Dept of State, No. 24-5204, 2024 WL 5286324, at *1
(D.C. Cir. Dec. 23, 2024) (per curiam) (“And no private right of action exists under 18 U.S.C. §
242.”), cert. denied sub nom. Wilson v. Dep t of State, 146 S. Ct. 1504 (2026); Crosby v. Catret,
308 F. App’x 453 (D.C. Cir. 2009) (per curiam) (affirming district court’s “reject[ion of] appellant’s
attempt to invoke 18 U.S.C. § 241 and 18 U.S.C. § 242 to initiate a prosecution against the named
defendants because there is no private right of action under these criminal statutes”); Renkel v.
United States, 456 F.3d 640, 644-45 (6th Cir. 2006) (noting that 18 U.S.C. §§ 2340 and 2340A
“criminalize torture outside the United States; they do not provide civil redress for torture within
the United States”); Sivokonev v. Cuomo, 447 F. Supp. 3d 58, 63 (W.D.N.Y. 2020) (“[I]t is well
settled that [18 U.S.C. § 2340] applies only to acts outside the United States, and in any event
refers to a criminal cause of action for which no private civil right of action exists.”).
It appears that Plaintiff has submitted, and the FBI has denied, see Compl., Ex. (ECF No.
1 at 3) an administrative tort claim under the Federal Tort Claims Act (“FTCA”), see 28 U.S.C. §§
1346, 2671-80. The complaint itself does not refer to the FTCA, and aside from vague references
to violations of Fourth and Fifth Amendment rights, see Compl. at 1, Plaintiff does not identify the
relevant tort(s), and any attempt to allege a constitutional tort against the United States of America
is futile. See Fed. Deposit Ins. Corp. v. Meyer, 510 U.S. 471, 477 (1994); see also Boling v. U.S.
Parole Comm’n, 290 F. Supp. 3d 37, 46 (D.D.C. 2017) (“First, the law is well established that
Congress has not waived the United States’ immunity with respect to tort claims arising under the
Constitution.”), aff'd, No. 17-5285, 2018 WL 6721354 (D.C. Cir. Dec. 19, 2018). As drafted, the
complaint lacks sufficient factual allegations supporting a viable legal claim.
An Order is issued separately.
/s/ Timothy J. Kelly
TIMOTHY J. KELLY
United States District Judge
Date: September 17, 2026