Ngambo v. Social Security Administration

Background

Jules Ngambo, representing himself, began the case by filing a notice of claim in the Town of Clarkstown Justice Court’s Small Claims Part. The notice sought a judgment of $3,000 plus costs based on the three-word assertion “Non-Payment of Invoices.” The Social Security Administration removed the action to the U.S. District Court for the Southern District of New York under 28 U.S.C. § 1442(a)(1).

The agency initially sought additional time to respond because it expected to file a motion challenging jurisdiction and the sufficiency of the claim. Instead, it filed a motion under Federal Rule of Civil Procedure 12(e) for a more definite statement. Ngambo did not respond.

The agency offered some context about a possible dispute involving Ngambo’s Certificate of Naturalization. According to the agency’s filings, Ngambo asserted that the agency had not returned the original document after he sent it while seeking an updated Social Security card. The agency also described an invoice seeking compensation for time and travel expenses. But the court noted that none of those details appeared in Ngambo’s notice of claim.

Rule 12(e) Standard

Rule 12(e) permits a party to request a more definite statement when a pleading is so vague or ambiguous that the party cannot reasonably prepare a response. The court explained that this remedy addresses unintelligible pleadings, not merely pleadings lacking additional detail. It also noted that courts may use the rule to balance the obligation to read self-represented parties’ pleadings liberally with the opposing party’s need to understand and answer the claims.

Court’s Analysis

The court held that Ngambo’s notice was excessively vague and ambiguous. It did not describe the invoices, identify the services for which payment was allegedly owed, explain the legal or factual basis for the Social Security Administration’s alleged obligation to pay, or identify the damages beyond the requested $3,000 and costs.

The information supplied by the agency was only its best guess about what Ngambo intended to claim. Because the notice did not provide enough information, the agency could not determine how to respond or evaluate possible threshold defenses, including questions about federal jurisdiction and whether an enforceable agreement to pay money existed.

Disposition

The court GRANTED the Social Security Administration’s motion for a more definite statement. It ordered Ngambo to file an amended complaint by January 3, 2024, identifying the invoices at issue, stating why the agency allegedly had to pay them, and stating the basis for the damages claimed. The amended complaint would completely replace the original notice of claim and become the operative pleading. The court also warned that failure to comply with a Rule 12(e) order could result in the pleading being stricken or another appropriate order.