Patrick Farrell v. Donald Trump, et al.

Summary

The United States District Court for the District of Arizona dismissed Patrick Farrell’s complaint against Donald Trump and Scott Bessent for lack of subject-matter jurisdiction. The court characterized the complaint as patently insubstantial and frivolous, including sovereign-citizen theories concerning birth-certificate bonds, and denied the motion to amend as moot.

Holdings

1. A complaint that is patently insubstantial and frivolous cannot support federal subject-matter jurisdiction and may be dismissed sua sponte under Federal Rule of Civil Procedure 12(b)(1). Farrell's complaint was sufficiently insubstantial and frivolous to require dismissal for lack of subject-matter jurisdiction.
2. The motion to amend the complaint was denied as moot after the complaint was dismissed for lack of subject-matter jurisdiction.

Questions Presented

1. Whether the complaint was so patently insubstantial and frivolous that it could not support federal subject-matter jurisdiction.
2. Whether the motion to amend should be decided after dismissal of the complaint for lack of subject-matter jurisdiction.

Disposition

dismissed