Farrell v. Trump, et al

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WO
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
Patrick Farrell,
Plaintiff,
v.
Donald Trump, et al.,
Defendants.
No. CV-26-02392-PHX-MTL
ORDER
Plaintiff Patrick Farrell filed a sealed complaint against President Donald Trump
and Secretary of the Treasury Scott Bessent. (Doc. 1.) The Court has since unsealed the
complaint. Broadly, the complaint is sprawling, largely incomprehensible, and filled with
derogatory statements. (See, e.g., id. at 14 (“Trump serves the Synagogue of Satan that
includes Israel, because they are stupid.”); id. at 28 (“All issues in this complaint come
from Jew Treasury funding, former Jews in ISKCON, former Jews in the mortgage
crisis . . . .”); id. at 32 (“This is why people of the world hate the Jews, because the Jews in
the Old Testament think they are better than all else and can take other’s lives without
‘remorse.’ Or sexually molest children in their care . . . .”); id. at 37 (accusing “[t]he Jews”
of, among other things, assassinating John F. Kennedy and orchestrating and profiting from
9/11).)
From what the Court can understand, Plaintiff appears to be unhappy with how the
current presidential administration is spending taxpayer funds that Plaintiff alleges
rightfully belong to him as interest on his birth certificate bond that was supposedly created
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when he was born and his birth certificate was “registered.” (See, e.g., id. at 7 (claiming
that Plaintiff is entitled to interest on “birth certificate bonds”); id. at 9-10 (similar); id. at
13 (same).) These appear to be sovereign citizen arguments,* which is consistent with
Plaintiff’s allegations indicating he believes himself to be a sovereign citizen. (See id. at 7
(calling himself a “Sovereign American”); id. at 13 (“I filed all Sovereignty Documentation
into the US Treasury and IRS and State and Federal Courts . . . .”); id. at 45 (“.09% of
people are Sovereigns like me.”).) Plaintiff alleges he is being tortured by the
administration’s actions because such actions have “compromised [his] good Spiritual
Karma that [he has] built up over [his] lifetime,” and by using the money he believes
belongs to him, the administration is making him a party to “illegal and sinful behavior.”
(Id. at 15; see also id. at 21; id. at 37 (“Trump has murdered thousands and Bessent has
given Trump the funds to do it from my account.”); id. at 41.) He also sets out sins and
biblical violations he believes the administration has committed. (See, e.g., id. at 37-41.)
Plaintiff’s motion to amend his complaint contains similar types of allegations.
(Doc. 6 at 1-2 (“Americans are debtors after the birth certificate was put into the Dept. of
Commerce and they must fund the debts of the U.S. except me, a Sovereign. The birth
certificate registration is not a valid contract and are not the surety for all unlawful debts
the corrupt Trump administration imposes on Americans.”); id. at 3 (advertising Plaintiff’s
book, which he alleges describes how people can “reclaim[] their birth certificates from
defendant US Treasury”); id. (stating that the government is funded by a financing
statement that “comes from the resources in GOD’s earth and life force in 300 million
citizens”); id. at 8 (“I no longer believe the United States of America exists, since the
parasitical fake Jews have taken over the US Treasury, the IRS, the Federal Reserve, the
Media and Wall Street, that are owned and operated by Jews who were blinded and cursed
* See, e.g., Patterson v. Yellen, No. 6:23-cv-01177-MC, 2023 WL 8477411, at *1 (D. Or.
Dec. 7, 2023) (“Many sovereign citizens subscribe to the ‘redemptionist’ theory and claim
they are owed money based on the issuance of their birth certificates.”); United States v.
Cook, No. 3:18-CR-00019, 2019 WL 2721305, at *2 (E.D. Tenn. June 28, 2019)
(“[S]overeigns believe they can use the court systems to access funds tied to their birth
certificate and Social Security numbers, through a tactic known as ‘redemption.’”); Bryant
v. Wash. Mut. Bank, 524 F. Supp. 2d 753, 758-59 (W.D. Va. 2007).
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by GOD . . . .”).)
“A patently insubstantial complaint may be dismissed . . . for want of subject-matter
jurisdiction under Federal Rule of Civil Procedure 12(b)(1).” Neitzke v. Williams, 490 U.S.
319, 327 n.6 (1989). “A federal claim which is so insubstantial as to be patently without
merit cannot serve as the basis for federal jurisdiction.” Trust v. Am. Honda Fin. Corp.,
No. 2:16-cv-1237-ODW-SS, 2016 WL 756461, at *2 (C.D. Cal. Feb. 25, 2016).
Additionally, “claims based on sovereign citizen arguments and ideology” are routinely
rejected as frivolous. See Patterson, 2023 WL 8477411, at *2 (dismissing frivolous
complaint for lack of subject matter jurisdiction). Having reviewed the complaint, the
Court finds that it is so insubstantial and frivolous that sua sponte dismissal for lack of
subject matter jurisdiction is appropriate.
IT IS THEREFORE ORDERED that the complaint is dismissed for lack of
subject matter jurisdiction. The Clerk of Court is directed to enter judgment accordingly
and close this case.
IT IS FURTHER ORDERED that the Motion to Amend Complaint (Doc. 6) is
denied as moot.
Dated this 23rd day of April, 2026.
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