UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA

BRENDA A. PATTERSON,

Plaintiff,

v.

FLORIDA DEPARTMENT OF CHILDREN 

AND FAMILIES, et al.,

Defendants.

Civil Action No. 21-1427 (RDM)

MEMORANDUM OPINION AND ORDER

Plaintiff Brenda A. Patterson, proceeding pro se, filed this action on May 26, 2021, 

against two Florida counties, a Florida state agency, the Clerk of the United States Supreme 

Court, and two private corporations. Dkt. 1 (Compl.). As this Court has previously described, 

see Patterson v. Fla. Dep’t of Children & Fams., No. 21-cv-1427, 2021 WL 6196991, at *1 

(D.D.C. Dec. 30, 2021), Plaintiff’s claims arise from the arrest and incarceration of Plaintiff’s 

son, Dimitri Patterson; allegations of forced medication during Dimitri’s time at a psychiatric 

facility; and subsequent efforts by Plaintiff and her son to vindicate what Plaintiff describes as 

the violation of their rights. Dkt. 3 (Am. Compl.). Plaintiff seeks a judgment of $300 million in 

actual damages; $60 million in “presumed damages;” and $60 million or 10% of Defendants’ net 

worth (whichever is greater) in punitive damages. Id. at 43 (Am. Compl.). This Court has 

previously dismissed four of the Defendants against whom Plaintiff initially brought suit: MiamiDade County, Hilton Worldwide Holdings, Inc. (“Hilton”), Wellpath Recovery Solutions, LLC. 

(“Wellpath”), and the Clerk of the Supreme Court, Scott S. Harris (“the Clerk”). Patterson, 2021 

WL 6196991, at *5. After that dismissal, only Orange County, Florida and the Florida 

Department of Children and Families remain as defendants.
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 Now before the Court is Defendant Orange County’s motion to dismiss for lack of 

personal jurisdiction and improper venue. Dkt. 56. For the reasons that follow, the Court will 

GRANT Defendant’s motion to dismiss. 

I.

Personal jurisdiction is, of course, a prerequisite to suit; except under rare circumstances 

not present here, “a federal court . . . may not rule on the merits of a case without first 

determining that it has jurisdiction over . . . the parties.” Sinochem Int’l Co. v. Malaysia Int’l 

Shipping Co., 549 U.S. 422, 430–31 (2007). On a motion to dismiss for lack of personal 

jurisdiction, “[t]he plaintiff has the burden of establishing a factual basis for the exercise of 

personal jurisdiction over the defendant[s].” Crane v. N.Y. Zoological Soc’y., 894 F.2d 454, 456 

(D.C. Cir. 1990). A plaintiff may establish personal jurisdiction by asserting either general 

jurisdiction—which “extends to any and all claims brought against a defendant”—or specific 

jurisdiction—which requires that “[t]he plaintiff ’s claims . . . arise out of or relate to the 

defendant’s contacts with the forum.” Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 141 S. Ct. 

1017, 1024–25 (2021) (internal quotation marks omitted). Plaintiff has not carried that burden 

here with respect to either form of personal jurisdiction, even accounting for the liberal pleading 

standard afforded pro se litigants. See Erickson v. Pardus, 551 U.S. 89, 94 (2007). 

As for general jurisdiction, Plaintiff makes no allegation that Orange County should be 

“fairly regarded as at home” in the District of Columbia, Goodyear Dunlop Tires Operations, 

S.A. v. Brown, 564 U.S. 915, 924 (2011). Orange County, moreover, expressly denies that 

notion, see Dkt. 56-1 at 9, and for good reason—Orange County is (self-evidently) “at home” in 

the Middle District of Florida. See Achagzai v. Broad. Bd. of Governors, 170 F. Supp. 3d 164, 
3

173 (D.D.C. 2016) (“[T]he Court may look beyond the allegations of the complaint . . . to satisfy 

itself that it has [personal] jurisdiction.”). 

As for specific jurisdiction, the amended complaint makes clear that, to the extent Orange 

County has engaged in any conduct in the District of Columbia, those activities “lack[] any 

connection to the plaintiff[’s] claims.” Ford Motor Co., 141 S. Ct. at 1031. The amended 

complaint locates each of the acts relevant to Orange County in Florida, including Dimitri

Patterson’s arrest by Orange County Police Officers in Orlando, Florida, Dkt. 3 at 3–7, 9 (Am. 

Compl. ¶¶ 16–36, 50), and his incarceration in the Orange County jail, id. at 7–8, 10–11 (Am. 

Compl. ¶¶ 37–40, 45, 56–62). Indeed, aside from Plaintiff’s allegation that the Clerk of the 

Supreme Court declined to docket several habeas petitions on behalf of her son, id. at 15 (Am. 

Compl. ¶¶ 85–91), Plaintiff makes no allegation that any event relevant to this case took place in 

or affected anyone in the District of Columbia. 

Plaintiff responds by pointing to 28 U.S.C. §§ 1331 and 1343, Fed. R. Civ. P. 4(k)(2)(A), 

42 U.S.C. § 1986, and various amendments to the U.S. Constitution, which, in her view, provide 

this Court with “jurisdiction over civil rights actions.” Dkt. 58 at 2. But 28 U.S.C. §§ 1331 and 

1343 speak to subject-matter jurisdiction, rather than personal jurisdiction, and although courts 

may exercise personal jurisdiction over defendants “based on the fact of in-state service of 

process,” Burnham v. Superior Ct. of Ca., 495 U.S. 604, 628 (1990) (emphasis added), Plaintiff 

nowhere alleges that Orange County or its representatives were served while physically present 

in the District of Columbia (if that were possible). And although 42 U.S.C. § 1986 and the 

Ninth, Thirteenth, and Fourteenth Amendments may provide substantive causes of action for 

suit, they do not speak to the Court’s personal jurisdiction over out-of-state defendants.
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Plaintiff fails altogether to address Orange County’s argument that all of the County’s 

alleged acts “occurr[ed] in [Florida].” Dkt. 56-1 at 10 (internal quotation marks omitted). 

Without the necessary nexus to the District of Columbia, the Court lacks personal jurisdiction 

over Defendant. The Court will, accordingly, grant Defendant Orange County’s motion to 

dismiss for lack of personal jurisdiction, Dkt. 56.

1

CONCLUSION

For the foregoing reasons, it is hereby ORDERED that the motion to dismiss filed by 

Orange County, Florida, Dkt. 56, is GRANTED.

SO ORDERED.

 /s/ Randolph D. Moss 

 RANDOLPH D. MOSS 

 United States District Judge 

1 Miami-Dade County also moves to quash service and argues that this Court is not the proper 

venue for this action. See Dkt. 56-1 at 7–8, 11–12. Although the County appears to be correct in 

both respects, the Court need not premise its decisions on these alternative grounds.