The D.C. Circuit Court of Appeals affirmed the dismissal of a lawsuit filed by Cheryl D. Uzamere against President Donald Trump and other federal officials, ruling that her complaint failed to meet basic federal pleading requirements.
In a judgment filed Dec. 31, 2025, the three-judge panel consisting of Circuit Judges Henderson, Wilkins, and Pan unanimously upheld a July 7, 2025 district court order dismissing Uzamere's case. The appeals court concluded that the district court correctly found that Uzamere's complaint did not satisfy fundamental pleading standards under federal law.
Uzamere filed the lawsuit both individually and in her capacity as sole proprietor of African Diasporal Enterprises and Uzamere Word Processing & More. She named Trump in his official capacity as President of the United States along with other unspecified federal officials as defendants in the case, which was originally filed in the U.S. District Court for the District of Columbia.
The central issue in the appeal centered on whether Uzamere's complaint met the basic requirements for federal civil litigation. Under Federal Rule of Civil Procedure 8(a), plaintiffs must provide "a short and plain statement of the claim showing that the pleader is entitled to relief." The Supreme Court established in *Bell Atlantic Corp. v. Twombly* (2007) that this statement must "give the defendant fair notice of what the claim is and the grounds upon which it rests."
The D.C. Circuit determined that Uzamere's complaint fell short of these fundamental requirements. The court found that the complaint failed to provide adequate notice to the defendants about the nature of the claims against them or the legal grounds supporting those claims. This deficiency rendered the complaint legally insufficient under established federal pleading standards.
On appeal, Uzamere raised several arguments challenging the district court's dismissal, but the D.C. Circuit found them "unavailing." The appeals court addressed two specific contentions raised by Uzamere in her appeal.
First, Uzamere argued that there were issues with how defendants were listed on the district court's docket. The D.C. Circuit noted that while the district court's docket currently lists each of the defendants named in Uzamere's complaint, she had not demonstrated that any initial docketing error would warrant reversal or vacatur of the dismissal order. The court determined that any such procedural issues were insufficient to overcome the substantive deficiencies in her pleadings.
Second, Uzamere contended that the district court should have granted her leave to amend her complaint. The D.C. Circuit rejected this argument, explaining that district courts are not required to sua sponte grant plaintiffs leave to amend their complaints. The court cited *Jones v. Horne* (D.C. Cir. 2011) as precedent for this principle. The appeals court noted that Uzamere had not identified any possible amendments that could cure the fundamental deficiencies in her original complaint.
The case proceeded through the appellate process on a streamlined basis. The D.C. Circuit considered the appeal based on the record from the district court and the brief filed by Uzamere, following Federal Rule of Appellate Procedure 34(a)(2) and D.C. Circuit Rule 34(j). This procedural posture suggests that the court found the legal issues sufficiently clear-cut to resolve without oral argument or additional briefing from the defendants.
The dismissal represents a complete victory for the Trump administration and other federal defendants in the case. The affirmance by the D.C. Circuit, which frequently handles cases involving federal agencies and officials, reinforces the importance of meeting basic pleading requirements in federal litigation, particularly in cases against government defendants.
The ruling underscores the ongoing application of the *Twombly* standard, which tightened federal pleading requirements when the Supreme Court decided that case in 2007. Under this standard, plaintiffs must provide more than conclusory allegations and must include factual content that allows courts to draw reasonable inferences that defendants are liable for the alleged misconduct.
For Uzamere, the unanimous affirmance effectively ends her legal challenge against the Trump administration through this particular lawsuit. The D.C. Circuit's judgment appears to be final, with no indication that further proceedings will occur at the district court level. The ruling also demonstrates the challenges individual plaintiffs and small business owners face when bringing federal lawsuits without meeting established procedural requirements.
The case serves as a reminder that federal courts strictly enforce pleading standards regardless of whether plaintiffs are represented by counsel or proceeding pro se. The D.C. Circuit's decision reinforces that all plaintiffs must comply with fundamental requirements for stating viable legal claims, even when suing high-profile government officials.