Case Information
WO
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Melissa Brooke Wright, No. CV-25-04051-PHX-KML Plaintiff, ORDER v. Alison Arrendale, et al.,
Defendants.
Plaintiff Melissa Brooke Wright filed a complaint alleging a “conspiracy to deprive [her] of constitutional rights.” (Doc. 1 at 1.) The complaint seeks an “emergency order for writ of prohibition of eviction/ejectment action” related to property Wright owns in Mesa. (Doc. 1 at 1.) The complaint and this case are dismissed.
Wright purports to be making a “special appearance as the secured part creditor and rightful, factual and true beneficiary of the Melissa Brooke Wright Estate.” (Doc. 1 at 2.) It appears Wright is the owner of property located in Mesa that is scheduled to be sold at a trustee’s sale. Wright alleges she paid the past-due amounts using an “IRS Payment” that directs the United States Treasury to pay the past-due amount on her behalf. (Doc. 1 at 9.) Wright named as defendants four individuals, a corporation, two LLCs, an LLP, the Maricopa County Superior Court, Maricopa County, and the State of Arizona. These defendants took actions in connection with the trustee’s sale that constituted “abuse of law or legal process[,]” including because certain defendants required her to “pay for said [m]ortgage with Federal Reserve [n]otes,” which “are not backed by gold or silver coin” as the U.S. Constitution allegedly requires. (Doc. 1 at 3–4.)
A court may dismiss a frivolous complaint for lack of jurisdiction. Tr. v. Am. Honda Fin. Corp. , No. 2:16-cv-1237-ODW-SS, 2016 WL 756461, at *2 (C.D. Cal. Feb. 25, 2016). A complaint qualifies as frivolous when it “lacks an arguable basis either in law or in fact.” Neitzke v. Williams , 490 U.S. 319, 325 (1989). There is no arguable basis when the facts alleged “are fanciful, fantastic and delusional.” Frost v. Office of Attorney Gen. , No. 17- cv-04983-JSW, 2018 WL 6704137, at *1 (N.D. Cal. Dec. 20, 2018) (citing Denton v. Hernandez , 504 U.S. 25, 33 (1992)). Wright’s complaint lacks an arguable basis in law or fact and is dismissed.
Wright’s complaint alleges she is appearing as a representative of her “estate,” complains the United States went off the gold standard, and incorporates a document showing she directed the United States Treasury to pay off a personal debt. These allegations are some of the hallmarks of filings by “sovereign-citizens.” See United States v. Murphy , 824 F.3d 1197, 1204 n.1 (9th Cir. 2016) (“sovereign citizens” believe they “can access virtually unlimited sums from secret accounts created for them when the United States went off the gold standard in 1933”). “Sovereign-citizen” arguments and claims have been “consistently and thoroughly rejected by every branch of the government for decades” and establish Wright’s complaint is patently frivolous such that the court lacks jurisdiction. [1] United States v. Studley , 783 F.2d 934, 937 n.3 (9th Cir. 1986) (plaintiff’s argument that she was not subject to the tax code because she is an “absolute, freeborn and natural individual” was frivolous and “utterly meritless”);
Accordingly, IT IS ORDERED the complaint (Doc. 1) is DISMISSED WITHOUT
PREJUDICE . The Clerk of Court shall enter judgment and close this case. Dated this 31st day of October, 2025. of Am., N.A. , No. 7:13-528, 2013 WL 6564657, at *2 (S.D. Tex. Dec. 13, 2013) (“[Sovereign citizen] teachings have never worked in a court of law—not a single time.”).
NOTES
[1] See also, e.g. , United States v. Benabe , 654 F.3d 753, 767 (7th Cir. 2011) (“Regardless of an individual’s claimed status . . . as a ‘sovereign citizen’ [or] a ‘secured-party creditor,’ . . . that person is not beyond the jurisdiction of the courts. These theories should be rejected summarily[.]”); United States v. Jagim , 978 F.2d 1032, 1036 (8th Cir. 1992) (defendant’s sovereign-citizen argument was “completely without merit” and “patently frivolous”); United States v. Schneider , 910 F.2d 1569, 1570 (7th Cir. 1990) (describing sovereign-citizen arguments as having “no conceivable validity in American law”); see also Harrison v. Gunnells , 9:23-00584-RMG-MHC, 2024 WL 4682522, at *7 (D.S.C. Sept. 10, 2024) (“Plaintiff cannot claim to be a sovereign independent of governmental authority while simultaneously asking the judicial system to grant him recourse.”); La Vell Harris v. County of Lake , 20-cv-09329-RMI, 2021 WL 2170138, at *1 n.1 (N.D. Cal. May 10, 2021) (describing the sovereign citizen ideology as a “highly unusual and thoroughly debunked system of beliefs” that “amount[s] to little more than a series of baseless and senseless conspiracy theories”); Banks v. Florida , No. 19-756, 2019 WL 7546620, at *1 (M.D. Fla. Dec. 17, 2019) (collecting cases and stating that legal theories espoused by sovereign citizens have been consistently rejected as “utterly frivolous, patently ludicrous, and a waste of . . . the court’s time, which is being paid by hard-earned tax dollars”) report and recommendation adopted , 2020 WL 108983 (M.D. Fla. Jan. 9, 2020); Wirsche v. Bank