Patrick Farrell v. Donald Trump, et al.
Trial Court Opinion
1 WO 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA
9 Patrick Farrell, No. CV-26-02392-PHX-MTL 10 Plaintiff, ORDER v. Donald Trump, et al., 13 Defendants.
15 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).)
26 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 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.”
11 (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.)
14 Plaintiff’s motion to amend his complaint contains similar types of allegations.
15 (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). byGOD....”).)
2 “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., 6|| No. 2:16-cv-1237-ODW-SS, 2016 WL 756461, at *2 (C.D. Cal. Feb. 25, 2016).
7|| Additionally, “claims based on sovereign citizen arguments and ideology” are routinely || rejected as frivolous. See Patterson, 2023 WL 8477411, at *2 (dismissing frivolous 9|| complaint for lack of subject matter jurisdiction). Having reviewed the complaint, the || Court finds that it is so substantial and frivolous that sua sponte dismissal for lack of || subject matter jurisdiction 1s appropriate.
12 IT IS THEREFORE ORDERED that the complaint is dismissed for lack of 13} subject matter jurisdiction. The Clerk of Court is directed to enter judgment accordingly 14]| and close this case.
15 IT IS FURTHER ORDERED that the Motion to Amend Complaint (Doc. 6) is 16]} denied as moot.
17 Dated this 23rd day of April, 2026.
20 Michael T, Liburdi 21 United States District Judge _3-
Case-law data current through December 31, 2025. Source: CourtListener bulk data.