Baldwin v. Small Business Administration

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA CLARENCE E. BALDWIN, Plaintiff, v. Civil Action No. 16-1365 (RDM) SMALL BUSINESS ADMINISTRATION, Defendant. MEMORANDUM OPINION Pro se complaints are “‘held to less stringent [pleading] standards than formal pleadings drafted by lawyers.’” Erickson v. Pardus,

551 U.S. 89, 94

(2007) (citation omitted). At some point, however, the Court cannot proceed with a case in the absence of a properly framed legal dispute. Here, the plaintiff, Clarence Baldwin, filed a FOIA action seeking records that the defendant, the Small Business Administration…