UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

EDWARD ALLAN WATTS and 

LINDSAY LOPEZ, 

Plaintiffs,

v. Civil Action No. 22-2146 (JEB)

U.S. DEPARTMENT OF JUSTICE, et al., 

Defendants.

MEMORANDUM OPINION 

Pro se Plaintiffs Edward Allan Watts and Lindsay Lopez, residents of Arkansas, have

filed this largely incomprehensible suit against a score of Defendants, including federal and state 

government entities, officials, and family members. A number of Arkansas-related Defendants 

now move to dismiss on multiple grounds, including lack of personal jurisdiction. As those 

Defendants are not sufficiently connected to the District of Columbia, the Court will grant the 

Motion.

I. Background

To fully describe the events that compose the basis of this action requires more powers 

than this Court can summon, as Plaintiffs catalog decades of incidents. A taste: Watts’s older 

brothers “began feeding him tobacco and alcohol as part of the grooming process for sexual 

abuse”; when he spoke of it, one “retaliated by throwing a large rock at the plaintiff”; he was 

subjected to hypnotism, along with which “came atheism, witchcraft, satanism, and other 

indoctrination”; years later, police in Fort Smith, Arkansas, “were rude and abusive”; University 

of Arkansas officials were not responsive; prosecutors refused to investigate; and so forth. See
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ECF No. 1 (Compl.) at ECF pp. 15, 18–21. Although there are a number of random references 

to the U.S. Code, no cause of action is specifically set forth. Plaintiffs nonetheless seek damages 

in the amount of $9,999,999,999.99. Id. at ECF p. 35.

Plaintiffs named 21 Defendants, including federal agencies, federal officials, state 

agencies, state officials, and other individuals. Given their failure to effect proper service, the 

Court previously dismissed half of the Defendants. See Minute Order of Dec. 8, 2022. Two 

current Motions to Dismiss from Arkansas-related Defendants now stand ripe. See ECF Nos. 9 

& 12.

II. Legal Standard

Under Federal Rule of Civil Procedure 12(b)(2), a defendant may move to dismiss a suit 

if the court lacks personal jurisdiction over it. The plaintiff bears the burden of establishing 

personal jurisdiction, FC Inv. Group LC v. IFX Markets, Ltd., 529 F.3d 1087, 1091 (D.C. Cir. 

2008), and the requirements for personal jurisdiction “must be met as to each defendant.” Rush 

v. Savchuk, 444 U.S. 320, 332 (1980). In deciding whether the plaintiff has shown a factual 

basis for personal jurisdiction over a defendant, the court resolves factual discrepancies in favor 

of the plaintiff. Crane v. N.Y. Zoological Soc’y, 894 F.2d 454, 456 (D.C. Cir. 1990). When 

personal jurisdiction is challenged, “the district judge has considerable procedural leeway in 

choosing a methodology for deciding the motion.” 5B Charles A. Wright & Arthur R. Miller et 

al., Federal Practice and Procedure § 1351 (3d ed. 2004). The court may rest on the allegations 

in the pleadings, collect affidavits and other evidence, or even hold a hearing. Id.

III. Analysis

Defendants offer a number of arguments in support of dismissal, but the Court need only 

address the issue of personal jurisdiction, which they correctly claim is lacking here. Personal 
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jurisdiction may either be in the form of general or specific jurisdiction. Goodyear Dunlop Tires 

Operations, S.A. v. Brown, 564 U.S. 915, 919 (2011). 

The Due Process Clause permits general jurisdiction over a non-resident defendant who 

maintains sufficiently systematic and continuous contacts with the forum state, regardless of 

whether those contacts gave rise to the claim in the particular suit. Helicopteros Nacionales de 

Colombia, S.A., v. Hall, 466 U.S. 408, 414–15 (1984). Where a plaintiff can show one of “a 

limited set of affiliations with a forum,” all of which are tantamount to a defendant’s domicile, 

Daimler AG v. Bauman, 571 U.S. 117, 137 (2014), general jurisdiction is appropriate. For 

corporations, general jurisdiction may be asserted if the forum is one in which the corporation is 

“fairly regarded as at home,” id. (quoting Goodyear, 564 U.S. at 924), which has been defined as 

generally being either its “place of incorporation” or its “principal place of business.” Id.

Specific jurisdiction, conversely, permits a court to adjudicate “issues deriving from, or 

connected with, the very controversy that establishes [the] jurisdiction.” Goodyear, 564 U.S. at 

919 (citation omitted). To show specific jurisdiction, a plaintiff must meet the requirements of 

the Due Process Clause and that jurisdiction’s long-arm statute. D.C.’s long-arm statute 

enumerates the kinds of contacts with the District that are sufficient to bring a non-resident 

defendant into a D.C. court:

(1) transacting any business in the District of Columbia;

(2) contracting to supply services in the District of Columbia;

(3) causing tortious injury in the District of Columbia by an act or omission in the 

District of Columbia;

(4) causing tortious injury in the District of Columbia by an act or omission 

outside the District of Columbia if [the defendant] regularly does or solicits 

business, engages in any other persistent course of conduct, or derives 

substantial revenue from goods used or consumed, or services rendered, in the 

District of Columbia;

(5) having an interest in, using, or possessing real property in the District of 

Columbia;
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(6) contracting to insure or act as surety for or on any person, property, or risk, 

contract, obligation, or agreement located, executed, or to be performed within 

the District of Columbia at the time of contracting, unless the parties 

otherwise provide in writing; or

(7) marital or parent and child relationship in the District of Columbia . . . .

D.C. Code § 13-423(a) (2012). 

In order to comport with due process, a nonresident defendant must have “certain 

minimum contacts with [the forum state] such that the maintenance of the suit does not offend 

traditional notions of fair play and substantial justice.” Int’l Shoe Co. v. Washington, 326 U.S. 

310, 316 (1945) (internal quotation marks omitted). Those guarantees are satisfied “if the 

defendant has ‘purposefully directed’ his activities at residents of the forum,” Burger King Corp. 

v. Rudzewicz, 471 U.S. 462, 472 (1985) (quoting Keeton v. Hustler Mag., Inc., 465 U.S. 770, 

774 (1985)), and if “the litigation results from alleged injuries that ‘arise out of or relate to’ those 

activities.” Id. (quoting Helicopteros, 466 U.S. at 414).

The filings demonstrate that neither type of jurisdiction exists here. Plaintiffs make no 

allegation in their Complaint or Opposition that any of these Defendants had any contacts —

either related to this claim or otherwise — with the District of Columbia. They are thus out of 

luck.

IV. Conclusion

Because the Court lacks personal jurisdiction over these Arkansas-based Defendants, the 

Court will grant their Motions to Dismiss. A separate Order consistent with this Memorandum 

Opinion shall issue this date.

/s/ James E. Boasberg

 JAMES E. BOASBERG

 United States District Judge

Date: December 9, 2022