Andray McWilliams v. Equal Employment Opportunity Commission and United States

Summary

The United States District Court for the Middle District of Florida grants the defendants’ motion for a more definite statement under Federal Rule of Civil Procedure 12(e). The court finds that the amended complaint is an impermissible shotgun pleading because it contains vague and conclusory allegations, fails to link facts to specific claims and defendants, and includes allegations concerning nonparties. The court also directs the plaintiff to provide facts sufficient to establish proper venue and requires a second amended complaint by February 27, 2026.

Holdings

1. The amended complaint was an impermissible shotgun pleading because it consisted largely of conclusory, vague, and immaterial allegations, failed to link factual allegations to cognizable claims, and did not specify which defendant was responsible for which acts or omissions.
2. A motion for a more definite statement was appropriate because the amended complaint failed to satisfy minimal federal pleading requirements and was too unintelligible to permit defendants to frame a responsive pleading.
3. The amended complaint did not allege sufficient facts to permit the court to determine whether venue was proper in the Middle District of Florida, so plaintiff was required to include additional venue-related facts in the second amended complaint.

Questions Presented

1. Whether plaintiff's amended complaint was so vague, conclusory, and improperly structured that defendants could not reasonably prepare a response under Federal Rules of Civil Procedure 8 and 12(e).
2. Whether the amended complaint adequately identified which defendants were responsible for which alleged acts and which factual allegations supported each claim.
3. Whether plaintiff's amended complaint alleged sufficient facts to permit the court to determine whether venue was proper in the Middle District of Florida under 28 U.S.C. § 1391(e)(1).

Disposition

other