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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

MEMORANDUM OPINION 

This matter comes before the Court on review of pro se Plaintiff Heidi Peterson’s

application to proceed in forma pauperis. The Court will grant the application, but dismiss the 

Complaint for lack of subject-matter jurisdiction because Plaintiff has not established standing to 

sue. See Fed. R. Civ. P. 12(h)(3) (requiring court to dismiss an action “at any time” if it 

determines that subject-matter jurisdiction is lacking); Haase v. Sessions, 835 F.2d 902, 906 

(D.C. Cir. 1987) (“[T]he defect of standing is a defect in subject matter jurisdiction.”).

I. Background

Plaintiff Heidi Peterson alleges that the “Federal Reserves [sic] is accused of artificially 

holding up housing prices through their quantitative easing policies.” Compl. at 2. According to 

Plaintiff, this leads to “homelessness” and “contribut[es] to the change in birth rate and racial 

demographic of the country[.]” Id. at 4. Plaintiff has explained how the policies had an effect on 

her and her family:

I was not able to live in what America offered me as affordable 

housing for my safety and safety of my child and I was not able to 

afford a home in a white community where I would probably not 

HEIDI PETERSON,

Plaintiff,

v. Civil Action No. 14-1053 (UNA)

BOARD OF GOVERNORS OF THE 

FEDERAL RESERVE SYSTEM,

 Defendant.
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of been a target of attack and discrimination because me like many 

others can’t enter the higher end housing market [sic].

Id. at 2.

Plaintiff refers to a specific attack that she was subjected to when “[t]he police refused to 

take police reports or investigate or send . . . prosecutors” when a gang took over Plaintiff’s 

house. Id. She claims that she needed to live in Detroit, “due to the fact it was one of the only 

places [she] had access to affordable housing, as [she] most likely could not get a loan.” Id. The 

gang purportedly took over her home because she could not live there while pregnant or with a 

child because there was lead-paint toxin. See id.

Plaintiff requests that this Court stop the “Federal Reserve[’]s Quantitative Easing 

program,” order the sale of mortgage-backed securities in the open market, and direct the Federal 

Reserve to “[r]epay the disenfranchised people . . . treble damages . . . by possibly placing them 

in homes they have been unable to buy or rent due to the artificial price fixing” among other 

relief. Id. at 7-8.

II. Analysis

Article III of the Constitution limits the power of the federal judiciary to the resolution of 

“Cases” and “Controversies.” Because “standing is an essential and unchanging part of the caseor-controversy requirement of Article III,” Lujan v. Defenders of Wildlife, 504 U.S. 555, 560 

(1992), finding that a plaintiff has standing is a necessary “predicate to any exercise of [the 

Court’s] jurisdiction.” Fla. Audubon Soc’y v. Bentsen, 94 F.3d 658, 663 (D.C. Cir. 1996); see 

also Allen v. Wright, 468 U.S. 737, 750 (1984) (discussing case-or-controversy requirement). 

“This limitation is no mere formality: it ‘defines with respect to the Judicial Branch the idea of 

separation of powers on which the Federal Government is founded.’” Dominguez v. UAL Corp., 

666 F.3d 1359, 1361 (D.C. Cir. 2012) (quoting Allen, 468 U.S. at 750). 
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The doctrine of standing “requires federal courts to satisfy themselves that ‘the plaintiff 

has alleged such a personal stake in the outcome of the controversy as to warrant [her] invocation

of federal-court jurisdiction.” Summers v. Earth Island Inst., 555 U.S. 488, 493 (2009) (citing 

Warth v. Seldin, 422 U.S. 490, 498-99 (1975)). “To establish Article III standing, an injury must 

be ‘concrete, particularized, and actual or imminent; fairly traceable to the challenged action; and 

redressable by a favorable ruling.’” Clapper v. Amnesty Intern. USA, 133 S. Ct. 1138, 1147 

(2013) (quoting Monsanto Co. v. Geertson Seed Farms, 130 S. Ct. 2743, 2747 (2010)).

While Plaintiff’s situation may be unfortunate, her claim fails to satisfy the last two 

elements of standing. It is unclear how the Federal Reserve’s policies caused Plaintiff the harm

she alleges, and it is even more speculative to assume that a favorable decision by this Court will

provide her the relief she desires.

Assuming Plaintiff’s loss of her home is a “concrete and particularized” injury, “the line 

of causation between [the Federal Reserve’s] conduct” and her injuries “is attenuated at best.” 

See Allen, 468 U.S. at 757; see also Vardon v. Fed. Reserve Sys., No. 11-1565, 2011 WL 

3847168, at *1 (D.D.C. Aug. 31, 2011) (dismissing plaintiff’s claim against Federal Reserve 

because Plaintiff’s financial losses were not fairly traceable to Federal Reserve’s allegedly failed 

policies), aff’d, 448 Fed. App’x 77 (D.C. Cir. 2012) (per curiam). Plaintiff claims that she had 

to live in Detroit because “she most likely could not get a loan.” See Compl. at 2. Then she 

alleges that because she had to live in Detroit, there was lead paint; when she became pregnant,

she needed to move out. See id. After this, a gang took over and the police did not investigate.

See id. The injury to Plaintiff is “highly indirect and ‘results from the independent action of 

[multiple] third part[ies] not before the court.’” See Allen, 468 U.S. at 758 (quoting Simon v. 

Eastern Kentucky Welfare Rights Org., 426 U.S. 26, 42 (1976)). Therefore, even if the Federal 
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Reserve’s policy adversely affected the housing market, it is entirely speculative to assume that 

Plaintiff’s harms were “fairly traceable” to Defendant’s conduct because there are too many links 

in the chain of causation. See Allen, 468 U.S. at 759 (“The links in the chain of causation 

between the challenged Government conduct and the asserted injury are far too weak for the 

chain as a whole to sustain respondents’ standing.”). 

Similarly, any inquiry into whether Plaintiff’s injuries are redressable by this Court 

would involve substantial guesswork. See ASARCO Inc. v. Kadish, 490 U.S. 605, 614 (1989) 

(opinion of Kennedy, J.) (“[I]t is pure speculation whether the lawsuit would result in any actual 

tax relief for respondents.”). If this Court were to order the Federal Reserve to stop its 

Quantitative Easing Program or order the sale of mortgaged-backed securities, the possible effect 

on the housing market would be entirely unclear. But even if the Court assumes that Plaintiff’s 

proposed policies would be beneficial to the United States economy, it is “pure speculation” to 

assume that this would fix Plaintiff’s problem of not being able to live in her desired house in her 

desired neighborhood. 

The Court, accordingly, will an issue an Order dismissing the case without prejudice.

 /s/ James E. Boasberg 

 JAMES E. BOASBERG

 United States District Judge

Date: June 20, 2014