Febrianti v. 2nd Circuit
CourtDistrict Court, District of Columbia
Date FiledOctober 28, 2026
DocketCivil Action No. 2026-2717
JudgeJudge Trevor N. McFadden
StatusPublished
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Full Opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
ERICA FEBRIANTI, )
)
Plaintiff, )
v. ) Civil Action No. 26-2717 (UNA)
)
2ND CIRCUIT, et al., )
)
Defendants. )
MEMORANDUM OPINION
This matter is before the Court on consideration of plaintiff’s 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 without prejudice.
Complaints filed by pro se litigants are held to “less stringent standards” than those
applied to pleadings drafted by lawyers. Haines v. Kerner, 404 U.S. 519, 520 (1972). Still, pro
se litigants must comply with the Federal Rules of Civil Procedure. Jarrell v. Tisch, 656 F. Supp.
237, 239 (D.D.C. 1987). Rule 8(a) of the Federal Rules of Civil Procedure requires that a
complaint contains a short and plain statement of the grounds upon which the court’s jurisdiction
depends, a short and plain statement of the claim showing that the pleader is entitled to relief,
and a demand for judgment for the relief the pleader seeks. FED. R. CIV. P. 8(a). It “does not
require detailed factual allegations, but it demands more than an unadorned, the-defendant-
unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quotations
omitted). In addition, Rule 8(d) states that “[e]ach allegation must be simple, concise, and
direct.” FED. R. CIV. P. 8(d)(1). “Taken together, [those provisions] underscore the emphasis
placed on clarity and brevity by the federal pleading rules.” Ciralsky v. CIA, 355 F.3d 661, 669
(D.C. Cir. 2004) (cleaned up). The Rule 8 standard ensures that defendants receive fair notice of
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the claim being asserted so that they can prepare a responsive answer, mount an adequate
defense, and determine whether the doctrine of res judicata applies. See Brown v. Califano, 75
F.R.D. 497, 498 (D.D.C. 1977).
The Court has reviewed the complaint and plaintiff’s additional submissions (ECF Nos.
6-9) and concludes that plaintiff fails to meet Rule 8’s minimal pleading standard. Rather, the
few intelligible factual allegations mention plaintiff’s stay in a homeless shelter in New York,
encounters with New York Police Department officers, alleged violations of her Fourth
Amendment rights, and cases plaintiff has filed (or attempted to file) in the U.S. Supreme Court,
the U.S. Court of Appeals for the Second Circuit, and the U.S. District Court for the Southern
District of New York, among other matters. Taken together, plaintiff’s submissions neither
articulate viable legal claims nor put defendants on notice of the claim or claims against them.
A separate Order will issue.
2026.10.28
DATE: October 28, 2026 09:55:48 -04'00'
TREVOR N. McFADDEN
United States District Judge
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