Internal Path Ecclesiastical Trust v. Toyota Motor Credit Corporation

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN MARIANA ISLANDS
INTERNAL PATH ECCLESIASTICAL
TRUST,
Plaintiff,
v.
TOYOTA MOTOR CREDIT
CORPORATION,
Defendant.
Case No. 1:25-cv-0007
DECISION AND ORDER DISMISSING
COMPLAINT WITHOUT PREJUDICE
AND WITHOUT LEAVE TO AMEND,
DENYING ALL OUTSTANDING
MOTIONS, AND CLOSING CASE
On August 22, 2025, Plaintiff Internal Path Ecclesiastical Trust (“the Trust”) filed a
Complaint against Defendant Toyota Motor Credit Corporation (“TMCC”) for declaratory relief
pursuant to 22 U.S.C. §2201 seeking a declaratory judgment confirming three matters: (1) that the
Trust holds a lawful secured interest in a private agreement assigned by its Trustee; (2) TMCC
failed to respond or cure after being served with formal notice and opportunity; and (3) that no
further administrative action is required before the Trust proceeds. (Compl. 2, ECF No. 1.) Before
the Court are the following seven motions, six of which were filed by Plaintiff:
(1) Plaintiff Internal Path Ecclesiastical Trust’s Motion for Leave to Use Electronic Filing
System (CM/ECF) (ECF No. 2), filed on September 3, 2025;
(2) Plaintiff Internal Path Ecclesiastical Trust’s Request for Clerk’s Entry of Default (ECF
No. 6), filed on October 20, 2025;
F I L E D
Clerk
District Court
for the Northern Mariana Islands
By________________________
(Deputy Clerk)
DEC 03 2025
Case 1:25-cv-00007 Document 17 Filed 12/03/25 Page 1 of 10

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(3) Plaintiff Internal Path Ecclesiastical Trust’s Motion to Strike Unauthorized and Untimely
Answer (ECF No. 9), filed on October 22, 2025;
(4) Plaintiff Internal Path Ecclesiastical Trust’s Motion for Default Judgment (Declaratory
Relief) (ECF No. 10), filed on October 23, 2025;
(5) Plaintiff Internal Path Ecclesiastical Trust’s Motion for Reconsideration and Clarification
of Order Granting Pro Hac Vice Admission (ECF No. 13), filed on November 5, 2025;
(6) Defendant Toyota Motor Credit Corporation’s Motion for Judgment on the Pleadings
Under Fed. R. Civ. P. 12(c) (ECF No. 14), filed on November 11, 2025; and
(7) Plaintiff Internal Path Ecclesiastical Trust’s Ex Parte Notice and Objection to Improper
Hearing and Preservation of Default Rights (ECF No. 16), filed on November 13, 2025.
The Trust is not represented by counsel, with Trustee Otis Lee Best III1 filing on behalf of the
Trust.
Upon a careful review of the Complaint in this matter, for the reasons set forth below, the
Court finds that it lacks subject-matter jurisdiction over the claims presented in the Complaint. As
such, the Court must dismiss the Complaint without prejudice, see Fed. R. Civ. P. 12(h)(3);
1 Mr. Best styles himself as “Otis-Lee: Best” throughout the Complaint and several of the exhibits attached
to the Complaint. (See, e.g., Compl. 1, ECF No. 1 (“Plaintiff, INTERNAL PATH ECCLESIATSICAL
TRUST, is a private trust, organized under ecclesiastical authority and operating by and through its Trustee,
Otis-Lee: Best, with a secured interest legally assigned and recorded.”); Compl., Ex. A, at 3 ¶ 4, ECF No.
1-2 (“The undersigned, Otis-Lee: Best, is the currently acting Trustee . . . .”).) The Court will refer to
Mr. Best without the colon and dash truncating his name, especially in view of his sworn representations
that he was named “Otis Lee Best III” at birth (see Compl., Ex. I, ¶ 10, ECF No. 1-10) and the use of such
punctuation, in conjunction with other theories asserted in the Complaint, as being consistent with sovereign
citizen-based theories that have been repeatedly rejected as frivolous in the federal courts, see, e.g., In re
Doughty, No. 1:25-cv-00400-JAW, 2025 WL 2418668, at *4 (D. Me. Aug. 21, 2025) (“The imposition of a
colon between one’s given name and surname, as here, is a hallmark of a sovereign citizen.”); Caetano v.
Internal Revenue Serv., No. 1:22-cv-00837-JLT-SAB, 2023 WL 3319158, at *2-4 (E.D. Cal. May 9, 2023)
(explaining sovereign citizen ideology and legal arguments and collecting cases), report and
recommendation adopted, 2023 WL 4087634 (E.D. Cal. June 20, 2023); Bryant v. Wash. Mut. Bank, 524
F. Supp. 2d 753, 758-61 (W.D. Va. 2007) (describing and rejecting attempt to avoid mortgage debt through
filing of Uniform Commercial Code Financing Statements).
Case 1:25-cv-00007 Document 17 Filed 12/03/25 Page 2 of 10

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Hampton v. Pac. Inv. Mgmt. Co. LLC, 869 F.3d 844, 846 (9th Cir. 2017) (“Dismissals for lack of
subject-matter jurisdiction . . . must be without prejudice, because a lack of jurisdiction deprives
the dismissing court of any power to adjudicate the merits of the case.”), and deny all outstanding
motions as moot. Furthermore, as the Complaint’s jurisdictional defects cannot be cured, the
Court’s dismissal of the Complaint is without leave for Plaintiff to amend and the Clerk of Court
is directed to close the case.
I. LEGAL STANDARD
“Federal courts are courts of limited jurisdiction. They possess only that power authorized
by the Constitution and statute . . . . It is to be presumed that a cause lies outside of this limited
jurisdiction, and the burden of establishing the contrary rests upon the party asserting jurisdiction.”
Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994) (citations omitted). Thus,
although “courts are generally limited to addressing the claims and arguments advanced by the
parties” and “do not usually raise claims or arguments on their own,” “federal courts have an
independent obligation to ensure that they do not exceed the scope of their jurisdiction, and
therefore they must raise and decide jurisdictional questions that the parties either overlook or elect
not to press.” Henderson ex rel. Henderson v. Shinseki, 562 U.S. 428, 434 (2011). “If the court
determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.”
Fed. R. Civ. P. 12(h)(3).
“To invoke a federal court’s subject-matter jurisdiction, a plaintiff needs to provide only ‘a
short and plain statement of the grounds for the court’s jurisdiction.’” Leite v. Crane Co., 749 F.3d
1117, 1121 (9th Cir. 2014) (quoting Fed. R. Civ. P. 8(a)(1)). In reviewing the allegations set forth
in the Complaint, the Court will accept all well-pleaded factual allegations as true and draw all
reasonable inferences in the Trust’s favor. Id.; see also Carolina Cas. Ins. Co. v. Team Equip., Inc.,
Case 1:25-cv-00007 Document 17 Filed 12/03/25 Page 3 of 10

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741 F.3d 1082, 1087 (9th Cir. 2014) (explaining that a party is not “required to plead jurisdiction
affirmatively based on actual knowledge” at pre-service, pre-answer stage of proceedings).
“Dismissal for lack of subject matter jurisdiction is appropriate if the complaint, considered in its
entirety, on its face fails to allege facts sufficient to establish subject matter jurisdiction.” In re
Dynamic Random Access Memory (DRAM) Antitrust Litig., 546 F.3d 981, 984-85 (9th Cir. 2008).
II. DISCUSSION
In its Complaint, the Trust, through Mr. Best,2 alleges the following facts.
(1) Mr. Best established the Trust in July 2025 with the filing of a “Certificate of Trust” in the
Gwinnett County Superior Court in Georgia, which Certificate names Mr. Best as Trustee.
(Compl. 2, ECF No. 1; Compl., Ex. A, ECF No. 1-2.)
(2) Mr. Best then filed a Uniform Commercial Code Financing Statement purporting to
“publicly assert[] [the Trust’s] secured interest over the individual named ‘OTIS LEE
2 Mr. Best is not an attorney. “Although a non-attorney may appear in propria persona in his own behalf,
that privilege is personal to him. He has no authority to appear as an attorney for others than himself.”
C.E. Pope Equity Tr. v. United States, 818 F.2d 696, 697 (9th Cir. 1987). “Consequently, in an action
brought by a pro se litigant, the real party in interest must be the person who ‘by substantive law has the
right to be enforced.’” Simon v. Hartford Life, Inc., 546 F.3d 661, 664 (9th Cir. 2008) (quoting C.E. Pope,
818 F.2d at 697).
The Complaint and accompanying “Certificate of Trust” do not identify any beneficiary of the
Internal Path Ecclesiastical Trust. Notwithstanding any issues concerning the validity of the Trust in view
of the lack of an identified beneficiary at the time of the Trust’s creation in Georgia, see, e.g., Ga. Code
Ann. § 53-12-20(b)(3), (c) (express trust requires designation of reasonably ascertainable beneficiary at
time of creation of trust or trust instrument sets forth selection criteria for beneficiary); cf. also Bey v. MUSC
Health Univ. Med. Ctr., No. 2:24-cv-03990-RMG-MGB, 2024 WL 3892379, at *5 (D.S.C. Aug. 1, 2024)
(finding nature of trust established pursuant to “national ecclesiastical trust indenture law” to be “frivolous”
and part of the “so-called ‘sovereign citizen’ movement”), report and recommendation adopted, 2024 WL
3891029 (D.S.C. Aug. 21, 2024), the Complaint fails to establish that Mr. Best is the real party in interest
who may appear as an attorney on the Trust’s behalf. In other words, “he cannot be viewed as a ‘party’
conducting his ‘own case personally’ within the meaning of [28 U.S.C. § 1654.] He may not claim that his
status as trustee includes the right to present arguments pro se in federal court.” C.E. Pope, 818 F.2d at
697-98. The Trust’s lack of legal representation is thus another basis to dismiss the Complaint without
prejudice and deny the Trust’s motions. Id.; see also Simon, 546 F.3d at 664-65 (collecting cases “adhering
to the general rule prohibiting pro se plaintiffs from pursuing claims on behalf of others in a representative
capacity”).
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BEST III.’” (Compl. 2; Compl., Ex. C, ECF No. 1-3 (identifying Mr. Best as debtor, the
Trust as secured party, and “[a]ll assets, property, accounts, proceeds, rights, titles,
entitlements, and beneficial interests, now existing or hereafter acquired by the Debtor,
including legal name, SSN ,all public and private records, commercial paper, contracts, and
rights to income” as collateral, and setting forth a “fee schedule” listing monetary penalties
“against any and all parties . . . who interfere with, infringe upon, or make authorized use
of the Debtor, the collateral, or the secured interest of the Trust”).)
(3) Thereafter, Mr. Best filed a Uniform Commercial Code Financing Statement Amendment
purporting to assign Mr. Best’s interest in a claim against TMCC to the Trust arising from
TMCC’s failure to respond to an “Affidavit of Default” that Mr. Best served on TMCC in
June 2025. (Compl. 2; Compl., Ex. C, ECF No. 1-4.)
(4) On July 29, 2025, Mr. Best served TMCC with copies of the Certificate of Trust, the
Financing Statement and Amendment, and a “Final Notice of Default and Opportunity to
Cure,” to which TMCC did not respond. (Compl. 2; Compl., Ex. D, ECF No. 1-5 (“Final
Ecclesiastical Notice of Default and Opportunity to Cure”); Compl., Ex. E, ECF No. 1-6
(certified mail receipt and tracking information for mailing to TMCC’s registered agent).)
(5) Prior to the purported assignment of his interest to the Trust, Mr. Best filed complaints with
federal and Georgia government agencies concerning TMCC’s wrongful acts and default
arising from Mr. Best’s purchase of a vehicle from a Lexus dealership in Gwinnett County,
which purchase was financed by TMCC.3 (Id.; Compl., Ex. F, ECF No. 1-7 (printout of
federal Consumer Financial Protection Bureau complaint and supplement); Compl., Ex. G,
3 The Complaint’s allegations do not describe the vehicle purchase and financing transaction; however, the
Court discerns the limited details concerning the underlying transaction from the printouts of Mr. Best’s
complaints to government agencies, as attached to the Complaint in this case.
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ECF No. 1-8 (printout of Georgia Attorney General’s Consumer Protection Division
consumer complaint form); Compl., Ex. H, ECF No. 1-9 (printout of Federal Reserve
Consumer Help complaint and email acknowledgement noting forwarding of complaint to
Federal Trade Commission).)
As to requested relief, the Trust seeks a declaratory judgment that:
1. Recognize[s] Internal Path Ecclesiastical Trust as the real party in
interest, lawfully assigned all rights, claims, and authority regarding
the subject matter, and acting by and through its authorized Trustee;
2. Affirm[s] the Trust’s standing to assert secured party rights and
enforce its interests, without third-party representation or rebuttal;
3. Declare[s] that Defendant failed to respond to or cure a properly
noticed claim, and that such silence constitutes acquiescence and
final commercial default;
4. Declare[s] that all non-judicial remedies were exhausted by the
assignor, and that Plaintiff may proceed in full authority under said
assignment; [and]
5. Grant[s] such other and further declaratory relief as the Court
deems just and proper.
(Compl. 3 (prayer for relief); see also id. at 2-3 (listing substantively identical questions to be
resolved by declaratory judgment under “Declaratory Relief Requested” section preceding prayer
for relief).) The Trust further disclaims that its Complaint sets forth any “claim for damages, lien
enforcement, or injunctive relief, but rather [is] a formal request to resolve legal uncertainties
regarding standing, jurisdiction, and unrebutted default.” (Compl. 2.)
The Complaint’s allegations and accompanying attachments fail to establish that the Court
has subject-matter jurisdiction over the Trust’s claims. The Trust invokes 28 U.S.C. § 1331 and
28 U.S.C. § 2201 as the basis for subject-matter jurisdiction. (Id. at 1.) The first provision sets
forth the Court’s federal-question jurisdiction: “[t]he district courts shall have original jurisdiction
of all civil actions arising under the Constitution, laws, or treaties of the United States.” 28 U.S.C.
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§ 1331. The second provision, as the first section of the Declaratory Judgment Act, provides in
relevant part:
In a case of actual controversy within its jurisdiction, . . . any court
of the United States, upon the filing of an appropriate pleading, may
declare the rights and other legal relations of any interested party
seeking such declaration, whether or not further relief is or could be
sought. Any such declaration shall have the force and effect of a
final judgment or decree and shall be reviewable as such.
28 U.S.C. § 2201(a).
The Trust’s reliance on 28 U.S.C. § 2201 as the relevant “law[] . . . of the United States”
under which its claims “aris[e,]” is misplaced. “A case ‘arises under’ federal law either [1] where
federal law creates the cause of action or [2] ‘where the vindication of a right under state law
necessarily turns on some construction of federal law.’” Republican Party of Guam v. Gutierrez,
277 F.3d 1086, 1088 (9th Cir. 2002) (original brackets omitted) (quoting Franchise Tax Bd. v.
Constr. Laborers Vacation Trust, 463 U.S. 1, 9 (1983)). As to the first possible basis for federal-
question jurisdiction, the Declaratory Judgment Act does not create a cause of action and thus
cannot be a standalone basis for jurisdiction. 28 U.S.C. § 2201(a) (“In a case of actual controversy
within its jurisdiction . . . .” (emphasis added)); California v. Texas, 593 U.S. 659, 672 (2021)
(“The Declaratory Judgment Act, 28 U.S.C. § 2201, alone does not provide a court with
jurisdiction.”); Gutierrez, 277 F.3d at 1089 (“The operation of the Declaratory Judgment Act is
procedural only. Congress enlarged the range of remedies available in the federal courts but did
not extend their jurisdiction.” (internal citation omitted) (quoting Skelly Oil Co. v. Phillips
Petroleum Co., 339 U.S. 667, 671 (1950))). The Trust does not identify any other federal law that
“creates [its] cause of action,” Gutierrez, 277 F.3d at 1088, and the Court discerns none. Therefore,
the Court must turn to the second possible basis for federal-question jurisdiction.
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As to the second possible basis for federal-question jurisdiction, the Trust’s allegations do
not show that its attempt at “vindication of a right under state law” through this case “necessarily
turns on some construction of federal law.” Id. Among the issues the Trust lists for resolution by
declaratory judgment (see Compl. 3), whether Mr. Best validly assigned his interests to the Trust,
such that the Trust may prosecute the claim against TMCC, is governed by state contract and
commercial law.4 Similarly, whether the Trust properly noticed its claim against TMCC and the
consequences of TMCC’s failure to respond to the Trust’s notice are governed by state law.
As to the Trust’s request for judicial findings concerning exhaustion of remedies and
perfection of its interest such that the Trust can bring suit against TMCC—which request appears
to be based on Mr. Best and the Trust’s attempt to obtain a declaratory judgment to invalidate any
debt or debt repayment obligations arising out of TMCC’s financing of Mr. Best’s purchase of a
vehicle (see Compl., Exs. F-H)5—the Supreme Court has explained:
[J]ust like suits for every other type of remedy, declaratory-
judgment actions must satisfy Article III’s case-or-controversy
4 The Uniform Commercial Code is not federal law; rather, it “is simply a set of model laws regarding the
governance of commercial transactions. It is not the ‘supreme law of the land,’ and has no formal
authority—it is merely a tool of legal scholarship.” Stoltenberg v. United States, No. 3:20-cv-00165-RRB,
2020 WL 6828028, at *3 (D. Alaska Nov. 20, 2020) (footnote omitted). The provisions of the Uniform
Commercial Code have the force of law only as adopted by the various states. See, e.g., In re Penrod, 392
B.R. 835, 855 (B.A.P. 9th Cir. 2008) (observing divergence among states concerning adoption of Uniform
Commercial Code provisions governing consumer purchase money security interests); Brown v. Jenkins,
218 S.E.2d 690, 694-95 (Ga. Ct. App. 1975) (“The Uniform Commercial Code, as enacted in 1962, applies
to transactions intended to create a security interest in personal property in this state. The Code provisions
are supplemented by more specific regulatory statutes which are controlling in case of conflict.” (emphasis
added))). As such, the Complaint’s allegations concerning creation and transfer of interests made pursuant
to statements filed under the Uniform Commercial Code raise issues of state law, not federal law.
5 “The relevant question concerns the nature of the threatened action in the absence of the declaratory
judgment suit.” Medtronic, Inc. v. Mirowski Fam. Ventures, LLC, 571 U.S. 191, 197 (2014). Presumably,
without the declaratory judgment action, TMCC would bring a suit under state contract or commercial law
to collect on its loan to Mr. Best, as secured by the vehicle Mr. Best purchased with TMCC’s financing,
whereupon Mr. Best would raise as a defense that TMCC’s loan or debt collection practices were invalid
or unlawful for the reasons set forth in Mr. Best’s complaints to federal and state agencies. Cf., e.g., Bryant,
524 F. Supp. 2d at 758-61 (attempt to avoid mortgage debt); Bey, 2024 WL 3892379, at *5-7 (attempt to
circumvent state domestic relations and child welfare laws).
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requirement. At a minimum, this means that the dispute must “be
‘real and substantial’ and ‘admit of specific relief through a decree
of a conclusive character, as distinguished from an opinion advising
what the law would be upon a hypothetical state of facts.’”
California, 593 U.S. at 672 (citations omitted) (quoting MedImmune, Inc. v. Genentech, Inc., 549
U.S. 118, 127 (2007)). The Trust does not identify an “imminent injury” it would suffer should a
declaratory judgment not issue, MedImmune, Inc., 549 U.S. at 130, or any “specific relief” apart
from “an opinion advising what the law would be,” California, 593 U.S. at 672 (quoting
MedImmune, Inc., 549 U.S. at 127). Thus, to the extent that the Trust may have claims that touch
upon federal law, the Court lacks subject-matter jurisdiction over such claims because there is no
actual case or controversy. See also Calderon v. Ashmus, 523 U.S. 740, 747 (1998) (finding no
case or controversy where plaintiff sought “a declaratory judgment as to the validity of a defense”
the defendant “may, or may not raise,” in a subsequent proceeding).
III. CONCLUSION
The Complaint fails to establish, on its face, that the Court has subject-matter jurisdiction
over the claims set forth therein because the Court’s federal-question jurisdiction does not extend
to a declaratory judgment action that relies solely upon the Declaratory Judgment Act, raises state
law issues, and fails to allege a case or controversy. The Court therefore lacks the authority to
proceed further with the Complaint, including any entry of default and default judgment
proceedings, and must dismiss the Complaint without prejudice. See also Jones v. Giles, 741 F.2d
245, 248 (9th Cir. 1984) (“Absence of subject matter jurisdiction may render a judgment void
where a court wrongfully extends its jurisdiction beyond the scope of its authority.”). As the
Complaint’s jurisdictional defects are not technical in nature and cannot be cured by amendment,
the Court’s dismissal of the Complaint is without leave to amend. Carolina Cas. Ins. Co., 741
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F.3d at 1087-88. The Court’s lack of authority to proceed also requires the denial as moot of all
outstanding motions in this matter. Accordingly,
(1) Plaintiff Internal Path Ecclesiastical Trust’s Complaint for Declaratory Relief (ECF No. 1)
is DISMISSED WITHOUT PREJUDICE and WITHOUT LEAVE TO AMEND for lack
of subject matter jurisdiction;
(2) Plaintiff Internal Path Ecclesiastical Trust’s (a) Motion for Leave to Use Electronic Filing
System (CM/ECF) (ECF No. 2), (b) Request for Clerk’s Entry of Default (ECF No. 6),
(c) Motion to Strike Unauthorized and Untimely Answer (ECF No. 9), (d) Motion for
Default Judgment (Declaratory Relief) (ECF No. 10), (e) Motion for Reconsideration and
Clarification of Order Granting Pro Hac Vice Admission (ECF No. 13), and (f) Ex Parte
Notice and Objection to Improper Hearing and Preservation of Default Rights (ECF
No. 16) are DENIED AS MOOT;
(3) Defendant Toyota Motor Credit Corporation’s Motion for Judgment on the Pleadings
Under Fed. R. Civ. P. 12(c) (ECF No. 14) is DENIED AS MOOT;
(4) The hearing on Defendant Toyota Motor Credit Corporation’s Motion for Judgment on the
Pleadings set for December 18, 2025, is VACATED; and
(5) The Clerk is directed to CLOSE the case.
IT IS SO ORDERED this 3rd day of December, 2025.
____________________________________
RAMONA V. MANGLONA
Chief Judge
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