Case: Does v. Patel

1:25-cv-04258 | U.S. District Court for the District of District of Columbia

Filed Date: Dec. 8, 2025

Case Ongoing

Clearinghouse coding complete

Case Summary

In the aftermath of the murder of George Floyd, tensions rose across the nation as civilians sought to end police brutality. On June 4, 2020, twenty-two Special Agents from the Federal Bureau of Investigation (FBI) were patrolling the D.C. area where a large crowd of indignant individuals gathered. The crowd was yelling, chanting, waving banners, and throwing objects. The Plaintiffs, now-former FBI Special Agents who were present that day, wanted to abide by the FBI’s Use of Force policy and no…

In the aftermath of the murder of George Floyd, tensions rose across the nation as civilians sought to end police brutality. On June 4, 2020, twenty-two Special Agents from the Federal Bureau of Investigation (FBI) were patrolling the D.C. area where a large crowd of indignant individuals gathered. The crowd was yelling, chanting, waving banners, and throwing objects. The Plaintiffs, now-former FBI Special Agents who were present that day, wanted to abide by the FBI’s Use of Force policy and not unnecessarily escalate the situation. However, the Plaintiffs were also not sufficiently equipped to handle the civil unrest as they lacked riot shields, gas masks, and helmets. Thus, the Plaintiffs started kneeling to de-escalate the situation, which ended up being successful. After the incident, the FBI and Department of Justice determined that these actions were consistent with FBI policy and there was no misconduct by the Plaintiffs.

 While the FBI and DOJ made it explicitly clear that the Plaintiffs would not face disciplinary consequences for the June 4th de-escalation, that changed when Kashyap Patel became the Director of the FBI on February 21, 2025, immediately, he began working to terminate all of the agents who kneeled, including the Plaintiffs. The FBI conducted an internal investigation in June 2025, and on September 26, 2025, the Plaintiffs and their colleagues received letters of termination. The letters reflected no individualized assessments for each plaintiff, but they said that the Plaintiffs and their colleagues were terminated for “unprofessional conduct and a lack of impartiality in carrying out duties, leading to the political weaponization of the government.” Thus, on December 8, 2025, the Plaintiffs filed a complaint against Patel, the FBI, Attorney General Pamela Bondi, the Department of Justice, and the Executive Office of the President (Defendants). The Plaintiffs filed their complaint in the United States District Court for the District of Columbia, and the case was assigned to Chief Judge James Boasberg. The Plaintiffs are represented by the Washington Litigation Group, but Plaintiff Jane Doe 6 is represented by John Kuchta Law, PLLC. This is an individual action.

 In their complaint, the Plaintiffs alleged violations of the First and Fifth Amendments. For the First Amendment freedom of association claim, the Plaintiffs alleged that the Defendants discharged them for not being supporters of the political party in power and President Donald Trump. They argued that while Patel praised the FBI agents from the January 6th insurrection in the U.S. Capitol, he was retaliating against Plaintiffs because they might not politically support Trump. The Plaintiffs also raised three claims under the Fifth Amendment’s Due Process Clause. First, the Plaintiffs alleged a due process-property violation. They argued that government employees have property interests because the government has “fostered rules and understandings” whereby employees believe that they will only lose their jobs for specified reasons. The Plaintiffs claimed they lived their lives assuming they would not be discharged for the June 4th incident and made critical life decisions, such as not resigning, because of this assumption. Second, the Plaintiffs alleged a due process-liberty violation, arguing that the Defendants’ public statements accusing the Plaintiffs of “unprofessional conduct,” “a lack of impartiality,” and “political weaponization of the government” were damaging to their professional reputations. Third, the Plaintiffs alleged a substantive due process violation, arguing that the Defendants abused government power and “shocked the conscience” of notions of fairness.

 Separately, Plaintiff Jane Doe 5 brought due process claims because of her role as an FBI Senior Executive Service Agent (SES). She alleged that her role required that she receive a hearing before her final termination, and that the lack of a 30-day notice was a separation of powers violation and the Defendants were acting ultra vires. 

 The Plaintiffs requested equitable relief, declaratory relief under the Declaratory Judgment Act (28 U.S.C. §§ 2201-2202), mandamus relief under 28 U.S.C. §1361, and any other appropriate relief. The Plaintiffs requested a writ of mandamus commanding Defendants to return Plaintiffs to their respective offices and a declaration that their constitutional rights were violated.

 On February 6, 2026, the Defendants moved to dismiss the Plaintiffs’ complaint for failure to state a claim. The Defendants argued that the same First Amendment protections do not apply to public employees performing their employment responsibilities, which the Plaintiffs were doing. The Defendants also moved to dismiss the Fifth Amendment claims, arguing that the property interest, reputation, and substantive due process claims were too abstract and factually unsupported. The Defendants also moved to dismiss Jane Doe 5’s claims, arguing that Article II gives the Executive the power to remove any inferior officer, and Doe was still subject to unrestricted approval. Moreover, the Defendants argued that Doe’s ultra vires claim was unfounded because there was no statutory provision requiring SES employees to have a hearing before their termination.

 On February 27, 2026, the Plaintiffs amended their complaint to include extensive detail about FBI policies protecting employees from political coercion, especially non-probationary employees like Jane Doe 5. Because of the amended complaint, the court dismissed the Defendants’ motion to dismiss as moot on February 27, 2026.

On March 4, 2026, Defendants filed a motion to dismiss Plaintiffs amended complaint. Defendants alleged that Plaintiffs failed to state a viable claim on any of their legal theories of the case.

This case is ongoing.

Summary Authors

Ameya Kamani (3/4/2026)

Nick Martire (3/6/2026)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/72004388/parties/does-v-patel/


Judge(s)

McFadden, Trevor Neil (District of Columbia)

Attorney for Plaintiff

Dohrmann, Mary Lyle (District of Columbia)

Kuchta, John David (District of Columbia)

Attorney for Defendant

Vaden, Andrew (District of Columbia)

show all people

Documents in the Clearinghouse

Document
1

1:25-cv-04258

Complaint

Does 1-9 v. Patel

Dec. 8, 2025

Dec. 8, 2025

Complaint
14

1:25-cv-04258

Motion to Dismiss and Memorandum in Support Thereof

Does 1-9 v. Patel

Feb. 6, 2026

Feb. 6, 2026

Magistrate Report/Recommendation
17

1:25-cv-04258

First Amended Complaint

Does 1-9 v. Patel

Feb. 27, 2026

Feb. 27, 2026

Complaint
18

1:25-cv-04258

Motion to Dismiss Plaintiffs' Amended Complaint and Memorandum in Support Thereof

March 4, 2026

March 4, 2026

Pleading / Motion / Brief

Docket

See docket on RECAP: https://www.courtlistener.com/docket/72004388/does-v-patel/

Last updated April 20, 2026, 3:23 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against All Defendants with Jury Demand ( Filing fee $ 405 receipt number ADCDC-12120084) filed by JOHN DOES, JANE DOES. (Attachments: # 1 Civil Cover Sheet Civil Cover Sheet, # 2 Summons SUMMONS of K. Patel, # 3 Summons SUMMONS of FBI, # 4 Summons SUMMONS of P. Bondi, # 5 Summons SUMMONS of DOJ, # 6 Summons SUMMONS of EOP, # 7 Summons SUMMONS of US)(Dohrmann, Mary) (Entered: 12/08/2025)

1 Civil Cover Sheet Civil Cover Sheet

View on PACER

2 Summons SUMMONS of K. Patel

View on PACER

3 Summons SUMMONS of FBI

View on PACER

4 Summons SUMMONS of P. Bondi

View on PACER

5 Summons SUMMONS of DOJ

View on PACER

6 Summons SUMMONS of EOP

View on PACER

7 Summons SUMMONS of US

View on PACER

Dec. 8, 2025

Dec. 8, 2025

Clearinghouse
2

SEALED MOTION to Proceed Under Pseudonym filed by JANE DOES, JOHN DOES (Attachments: # 1 Text of Proposed Order Proposed Order, # 2 Exhibit Sealed Attachment)(Dohrmann, Mary) (Entered: 12/08/2025)

Dec. 8, 2025

Dec. 8, 2025

3

NOTICE of Appearance by John David Kuchta on behalf of JANE DOES (Kuchta, John) (Entered: 12/09/2025)

Dec. 9, 2025

Dec. 9, 2025

4

CIVIL COVER SHEET by JOHN DOES, JANE DOES re 1 Complaint, filed by JOHN DOES, JANE DOES. Related document: 1 Complaint, filed by JOHN DOES, JANE DOES.(Dohrmann, Mary) (Entered: 12/09/2025)

Dec. 9, 2025

Dec. 9, 2025

Notice of Error- New Case

Dec. 9, 2025

Dec. 9, 2025

NOTICE OF NEW CASE ERROR regarding 1 Complaint,. The following error(s) need correction: Incorrect civil cover sheet. Please locate the Civil Cover Sheet (JS44) form at www.dcd.uscourts.gov/new-case-forms & file using the event Civil Cover Sheet. COMPLIANCE DEADLINE is by close of business today. This case will not proceed any further until all errors are satisfied. (znmw)

Dec. 9, 2025

Dec. 9, 2025

5

MEMORANDUM OPINION AND ORDER: The Court ORDERS that: 1) Plaintiffs' 2 Motion to Proceed Under Pseudonyms is GRANTED, subject to any further consideration by the United States District Judge to whom this case is randomly assigned; 2) All parties shall use the pseudonyms listed in the Complaint in all documents filed in this action; and 3) Within fourteen days of this Order, Plaintiffs shall file: i) A pseudonymous version of their 2 Motion on the public docket; and ii) A sealed declaration containing their real names and residential addresses. Signed by Chief Judge James E. Boasberg on December 15, 2025. (lcjeb4) (Entered: 12/15/2025)

Dec. 15, 2025

Dec. 15, 2025

6

SUMMONS (6) Issued Electronically as to All Defendants and U.S. Attorney General (Attachments: # 1 Notice and Consent)(znmw) (Entered: 12/16/2025)

Dec. 16, 2025

Dec. 16, 2025

Notice of Error- New Case

Dec. 16, 2025

Dec. 16, 2025

Case Assigned/Reassigned

Dec. 16, 2025

Dec. 16, 2025

Case Assigned to Judge Trevor N. McFadden. (znmw)

Dec. 16, 2025

Dec. 16, 2025

NOTICE OF NEW CASE ERROR regarding 1 Complaint,. The following error(s) need correction: Missing summonses- U.S. government. When naming a U.S. government agent or agency as a defendant, you must supply a summons for each defendant & two additional summonses for the U.S. Attorney. Please submit using the event Request for Summons to Issue. (znmw)

Dec. 16, 2025

Dec. 16, 2025

7

STANDING ORDER Establishing Procedures for Cases Before Judge Trevor N. McFadden. The parties are hereby ORDERED to read and comply with the directives in the attached standing order. Signed by Judge Trevor N. McFadden on 12/17/2025. (lctnm3). (Entered: 12/17/2025)

Dec. 17, 2025

Dec. 17, 2025

RECAP
8

REQUEST FOR SUMMONS TO ISSUE filed by JOHN DOES, JANE DOES. Related document: 1 Complaint, filed by JOHN DOES, JANE DOES.(Dohrmann, Mary) (Entered: 12/17/2025)

Dec. 17, 2025

Dec. 17, 2025

9

SUMMONS (1) Issued Electronically as to U.S. Attorney (mg) (Entered: 12/18/2025)

Dec. 18, 2025

Dec. 18, 2025

10

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. All Defendants (Attachments: # 1 Exhibit Proof of Service)(Dohrmann, Mary) (Entered: 12/18/2025)

Dec. 18, 2025

Dec. 18, 2025

11

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 12/8/2025. Answer due for ALL FEDERAL DEFENDANTS by 2/6/2026. (Attachments: # 1 Exhibit Proof of Service)(Dohrmann, Mary) (Entered: 12/22/2025)

Dec. 22, 2025

Dec. 22, 2025

12

NOTICE of Filing on the Public Docket of Plaintiffs' Motion for Leave to Proceed Under Pseudonyms and Memorandum in Support by JANE DOES, JOHN DOES re 5 Order on Sealed Motion to Proceed Under Pseudonym,, (Attachments: # 1 Plaintiffs' Motion for Leave to Proceed Under Pseudonyms and Memorandum in Support)(Dohrmann, Mary) (Entered: 12/22/2025)

Dec. 22, 2025

Dec. 22, 2025

13

SEALED DOCUMENT filed by JANE DOES, JOHN DOES re 5 Order on Sealed Motion to Proceed Under Pseudonym,, (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Declaration)(Dohrmann, Mary) (Entered: 12/22/2025)

Dec. 22, 2025

Dec. 22, 2025

Notice of Error

Dec. 22, 2025

Dec. 22, 2025

NOTICE OF ERROR regarding 10 Summons Returned Executed as to Federal Defendant. The following error(s) need correction: Incorrect event. Please refile with SUMMONS RETURNED EXECUTED as to US Attorney event. (mg)

Dec. 22, 2025

Dec. 22, 2025

14

MOTION to Dismiss by PAMELA J. BONDI, EXECUTIVE OFFICE OF THE PRESIDENT, FEDERAL BUREAU OF INVESTIGATION, KASHYAP P. PATEL, U.S. DEPARTMENT OF JUSTICE, UNITED STATES OF AMERICA. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit Ex. A - AG Bondi Memorandum)(Vaden, Andrew) (Entered: 02/06/2026)

1 Text of Proposed Order

View on PACER

2 Exhibit Ex. A - AG Bondi Memorandum

View on RECAP

Feb. 6, 2026

Feb. 6, 2026

Clearinghouse
15

SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by PAMELA J. BONDI, EXECUTIVE OFFICE OF THE PRESIDENT, FEDERAL BUREAU OF INVESTIGATION, KASHYAP P. PATEL, U.S. DEPARTMENT OF JUSTICE, UNITED STATES OF AMERICA (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Text of Proposed Order, # 2 Certificate of Service, # 3 Exhibit 1 - Unredacted Rule 10(a) Motion, # 4 Exhibit 2 - Redacted Rule 10(a) Motion)(Vaden, Andrew) (Entered: 02/06/2026)

Feb. 6, 2026

Feb. 6, 2026

16

MOTION for Briefing Schedule by JANE DOES, JOHN DOES. (Attachments: # 1 Text of Proposed Order)(Dohrmann, Mary) (Entered: 02/11/2026)

1 Text of Proposed Order

View on PACER

Feb. 11, 2026

Feb. 11, 2026

Order on Motion for Briefing Schedule AND Set/Reset Deadlines

Feb. 11, 2026

Feb. 11, 2026

MINUTE ORDER: The 16 Motion for a Briefing Schedule is GRANTED IN PART. Plaintiffs' Response to the 14 Motion to Dismiss is due by March 9, 2026. Defendants' reply, if any, in support of the 14 Motion to Dismiss is due by March 23, 2026. The Court will consider together the 15 Motion to Seal and the [15-3] Underlying Motion. Plaintiffs should file a combined response to those motions by March 9, 2026. Defendants may file a combined reply to those motions by March 23, 2026. SO ORDERED. Signed by Judge Trevor N. McFadden on 2/11/2026. (lctnm3).

Feb. 11, 2026

Feb. 11, 2026

17

AMENDED COMPLAINT (First) against All Defendants with Jury Demand filed by JOHN DOES, JANE DOES. (Attachments: # 1 Exhibit Redline - First Amended Complaint)(Dohrmann, Mary) (Entered: 02/27/2026)

1 Exhibit Redline - First Amended Complaint

View on RECAP

Feb. 27, 2026

Feb. 27, 2026

Clearinghouse

~Util - Set/Reset Deadlines

Feb. 27, 2026

Feb. 27, 2026

MINUTE ORDER: In light of the 17 Amended Complaint, the 14 Motion to Dismiss is DENIED AS MOOT. Defendants should answer or otherwise respond to the 17 Amended Complaint by March 13, 2026. The previously set deadlines for the 15 Motion to Seal and the [15-3] Underlying Motion remain in effect. See Feb. 11, 2026 Minute Order. Plaintiffs should file a combined response to those motions by March 9, 2026. Defendants may file a combined reply to those motions by March 23, 2026. SO ORDERED. Signed by Judge Trevor N. McFadden on 2/27/2026. (lctnm3).

Feb. 27, 2026

Feb. 27, 2026

18

MOTION to Dismiss PLAINTIFFS' AMENDED COMPLAINT by PAMELA J. BONDI, EXECUTIVE OFFICE OF THE PRESIDENT, FEDERAL BUREAU OF INVESTIGATION, KASHYAP P. PATEL, U.S. DEPARTMENT OF JUSTICE, UNITED STATES OF AMERICA. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A - AG Memorandum)(Vaden, Andrew) (Entered: 03/04/2026)

1 Text of Proposed Order

View on PACER

2 Exhibit A - AG Memorandum

View on RECAP

March 4, 2026

March 4, 2026

Clearinghouse
19

RESPONSE re 15 SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by PAMELA J. BONDI, EXECUTIVE OFFICE OF THE PRESIDENT, FEDERAL BUREAU OF INVESTIGATION, KASHYAP P. PATEL, U.S. DEPARTMENT OF JUSTICE, UNITED STATES OF AMERICA (This document is SEALED and only av and OPPOSITION re [15-4] DEFENDANTS' RULE 10(a) MOTION filed by JANE DOES, JOHN DOES. (Dohrmann, Mary) (Entered: 03/09/2026)

March 9, 2026

March 9, 2026

RECAP
20

First MOTION for Extension of Time to File Response/Reply as to 18 MOTION to Dismiss PLAINTIFFS' AMENDED COMPLAINT by JANE DOES, JOHN DOES. (Attachments: # 1 Text of Proposed Order)(Dohrmann, Mary) (Entered: 03/11/2026)

March 11, 2026

March 11, 2026

Order on Motion for Extension of Time to File Response/Reply AND Set/Reset Deadlines

March 12, 2026

March 12, 2026

MINUTE ORDER: The 20 Motion for Extension of Time is GRANTED. Plaintiffs' response to the 18 Motion to Dismiss is now due by April 3, 2026. Any reply in support of the motion to dismiss is due by April 17, 2026. SO ORDERED. Signed by Judge Trevor N. McFadden on 3/12/2026. (lctnm3).

March 12, 2026

March 12, 2026

21

REPLY to opposition to motion re 15 Sealed Motion for Leave to File Document Under Seal, filed by PAMELA J. BONDI, EXECUTIVE OFFICE OF THE PRESIDENT, FEDERAL BUREAU OF INVESTIGATION, KASHYAP P. PATEL, U.S. DEPARTMENT OF JUSTICE, UNITED STATES OF AMERICA. (Vaden, Andrew) (Entered: 03/23/2026)

March 23, 2026

March 23, 2026

RECAP
22

Memorandum in opposition to re 18 MOTION to Dismiss PLAINTIFFS' AMENDED COMPLAINT filed by JANE DOES, JOHN DOES. (Dohrmann, Mary) (Entered: 04/03/2026)

April 3, 2026

April 3, 2026

RECAP
23

REPLY to opposition to motion re 18 Motion to Dismiss, filed by PAMELA J. BONDI, EXECUTIVE OFFICE OF THE PRESIDENT, FEDERAL BUREAU OF INVESTIGATION, KASHYAP P. PATEL, U.S. DEPARTMENT OF JUSTICE, UNITED STATES OF AMERICA. (Vaden, Andrew) (Entered: 04/17/2026)

April 17, 2026

April 17, 2026

Case Details

State / Territory:

District of Columbia

Case Type(s):

Speech and Religious Freedom

Policing

Special Collection(s):

Police Violence Protests

Trump Administration 2.0: Challenges to the Government

Key Dates

Filing Date: Dec. 8, 2025

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

The Plaintiffs are anonymous former FBI agents who were present at the June 4, 2020 BLM protests in D.C.

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Defendant Type(s):

Law-enforcement

Case Details

Causes of Action:

Declaratory Judgment Act, 28 U.S.C. § 2201

Constitutional Clause(s):

Due Process

Due Process: Substantive Due Process

Other Dockets:

District of District of Columbia 1:25-cv-04258

Available Documents:

Complaint (any)

Trial Court Docket

Outcome

Prevailing Party: None Yet / None

Relief Sought:

Declaratory judgment

Injunction

Relief Granted:

None yet

Source of Relief:

None yet

Content of Injunction:

Reinstatement (job, contract, grant, etc.)

Issues

General/Misc.:

Discharge & termination plans

Discrimination Area:

Discharge / Constructive Discharge / Layoff

Discipline

Disparate Treatment

Presidential/Gubernatorial Authority:

Civil Service

Recommended Citation