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United States Court of Appeals, Seventh Circuit.

Eloise K. HAHN, Plaintiff-Appellant, v. BANK OF AMERICA, et al., Defendants-Appellees.

No. 17-3563

Decided: December 07, 2018

Before MICHAEL S. KANNE, Circuit Judge, AMY C. BARRETT, Circuit Judge, MICHAEL B. BRENNAN, Circuit Judge Eloise K. Hahn, Pro Se


Eloise Hahn sued Bank of America, Stifel Financial Corporation, and Herman Marino for violating the terms of an irrevocable trust, stealing her identity, and pilfering her tax refunds. The district court dismissed Hahn’s complaint for failure to state a claim, finding that it did not establish a basis for jurisdiction, did not identify particular claims against particular defendants, and did not state how Hahn was entitled to relief. When Hahn did not cure those problems in her amended complaint, the district court dismissed the case with prejudice.

On appeal, Hahn repeats her allegations—which are extremely difficult, if not impossible, to follow—from her complaint, but she has neither engaged with the district court’s reasoning nor cited any legal authority. We construe pro se filings liberally, Anderson v. Hardman, 241 F.3d 544, 545 (7th Cir. 2001), but even pro se litigants must comply with Federal Rule of Appellate Procedure 28(a)(8), see Anderson, 241 F.3d at 545–46, which requires that a brief contain a cogent argument and citations to authority. Because Hahn has not presented an argument, and because we see no obvious errors, the appeal is DISMISSED.

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