SPENCE v. U.S. DEP'T OF VETERANS AFFAIRS

No. 22-5273.

109 F.4th 531 (2024)

Jo SPENCE, Appellant v. UNITED STATES DEPARTMENT OF VETERANS AFFAIRS and Denis McDonough, in his official capacity as Secretary of the United States Department of Veterans Affairs, Appellees.

United States Court of Appeals, District of Columbia Circuit.

Decided July 23, 2024.


Attorney(s) appearing for the Case

Jo Spence, pro se, argued the cause and filed the briefs for appellant.

Bradley G. Silverman, Assistant U.S. Attorney, argued the cause for appellees. With him on the brief were Brian P. Hudak and Jane M. Lyons, Assistant U.S. Attorneys. R. Craig Lawrence, Assistant U.S. Attorney, entered an appearance.

Before: Millett, Katsas, and Rao, Circuit Judges.


Does the pleading leniency we afford pro se litigants apply when the litigant is a licensed attorney? We conclude it does not. Trained lawyers are generally not unsophisticated litigants in need of special protections, and any leniency afforded is left to the discretion of the district court.

In this case, Jo Spence was...

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