Quiel v. United States of America

CourtDistrict Court, D. Arizona
DecidedFebruary 22, 2024
Docket2:22-cv-02175
StatusUnknown

This text of Quiel v. United States of America (Quiel v. United States of America) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Quiel v. United States of America, (D. Ariz. 2024).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Michael L Quiel, No. CV-22-02175-PHX-DLR

10 Plaintiff, ORDER

11 v.

12 United States of America, et al.,

13 Defendants. 14 15 16 Plaintiff Michael L. Quiel is suing Defendants Cheryl Bradley, Monica Edelstein, 17 Timothy Stockwell, Christopher Rusch (now known as Christian Reeves), and the United 18 States Internal Revenue Service (“IRS”) for various federal and state law claims. Pending 19 before the Court are the United States’ motion to dismiss (Doc. 26), Edelstein and 20 Stockwell’s motion to dismiss (Doc. 27), Bradley’s motion to dismiss (Doc. 45), and 21 Plaintiff’s motion for default judgment (Doc. 48). The motions are fully briefed.1 (Docs. 22 26–30, 45–48.) 23 For the reasons set forth below, the Court grants the United States’ motion to dismiss 24 (Doc. 26), Edelstein and Stockwell’s motion to dismiss (Doc. 27), and Bradley’s motion to 25 dismiss (Doc. 45). The Court denies Plaintiff’s motion for default judgment (Doc. 48) and 26 orders Plaintiff to show cause within fourteen days why this case should not be dismissed. 27 1 Oral argument is denied because the issues are adequately briefed, and oral 28 argument will not assist the Court in reaching its decision. See Fed. R. Civ. P. 78(b); LRCiv. 7.2(f). 1 I. BACKGROUND2 2 On December 27, 2022, Plaintiff initiated this action, alleging that he “was the 3 unfortunate victim of an ill-conceived internal investigation by IRS agents” in conjunction 4 with unidentified individuals “as part of the government’s attempt to identify and 5 crackdown on U.S. Citizens who held foreign bank accounts and who . . . failed to register 6 and/or report same as required by law.” (Doc. 6 ¶ 12.) 7 Plaintiff claims that, in 2006, he and an unidentified business partner sought to 8 expand their unidentified business activities and so they retained Rusch, a licensed attorney 9 who held himself out as a specialist in the formation and structure of international corporate 10 entities. (¶¶ 13, 14.) After Plaintiff provided Rusch with his personal identifying 11 information, Rusch allegedly engaged in identity theft, impersonating Plaintiff and his 12 business partner in the operation of foreign bank accounts. (¶ 16.) While still advising 13 Plaintiff as his attorney, Rusch—who allegedly was a person of interest in an active IRS 14 investigation—met with IRS agents and “provided documents to them, in [an] effort[] to 15 curry favor for himself.” (¶ 22.) Plaintiff claims Rusch violated attorney-client privilege 16 and falsely implicated Plaintiff in illegal schemes. (¶ 23.) 17 Plaintiff asserts that these foreign accounts ultimately served as the grounds for 18 “unlawful” criminal and civil proceedings brought against Plaintiff.3 (¶ 16.) In 2011, 19 Plaintiff was indicted for various financial crimes, including conspiracy to defraud the 20 United States (18 U.S.C. § 371), making and subscribing a false tax return (26 U.S.C. 21 § 7206(1)), and willful failure to file a Report of Foreign Bank and Financial Accounts 22 (“FBAR”) (31 U.S.C. §§ 5314, 5322(a)). United States v. Quiel, No. 2:11-cr-02385-JAT- 23 2 (D. Ariz.) (Doc. 4.) In 2013, Plaintiff’s charges were tried before a jury. Bradley, an IRS 24 2 This section draws from the allegations in the First Amended Complaint (“FAC”) 25 (Doc. 6), which are accepted as true for the purpose of resolving the various Rule 12(b)(6) motions and in ruling on the motion for default judgment. 26 3 Despite being the basis for Plaintiff’s claims against Defendants, Plaintiff does not identify any of these proceedings in his FAC. Thus, the Court goes outside of the FAC and 27 takes judicial notice of such actions. United States ex rel. Robinson Rancheria Citizens Council v. Borneo, Inc., 971 F.2d 244, 248 (9th Cir. 1992) (“[W]e may take notice of 28 proceedings in other courts . . . if those proceedings have a direct relation to matters at issue.”). 1 agent, testified at the trial, and Edelstein and Stockwell, both Assistant United States 2 Attorneys, prosecuted the charges. 3 Plaintiff claims that Rusch and Bradley “gave false testimony, under oath at trial in 4 coordination with the ultra vires prosecution of the Plaintiff by defendants.” (Doc. 6 ¶ 25.) 5 Plaintiff further asserts that Edelstein, Bradley, and Rusch (no mention of Stockwell, 6 though he’s a named defendant) “acted with actual malice and conspired to present perjured 7 testimony to the Court and jury, under oath resulting in the erroneous conviction of the 8 Plaintiff.” (¶ 26.) Plaintiff alleges that this “was accomplished by additional skullduggery 9 by denying Plaintiff access to his Master IRS file which contained evidence necessary to 10 prove the foregoing assertions.” (¶ 28.) 11 The jury convicted Plaintiff of willful subscription to false tax returns—which 12 Plaintiff alleges is a “wrongful” conviction—and acquitted him of conspiracy to defraud 13 the United States. Quiel, No. 2:11-cr-02385-JAT-2 (Doc. 289.) The jury could not come to 14 an agreement as to whether Plaintiff willfully failed to file FBARs, so the judge declared a 15 mistrial on these counts. Id. (Docs. 281, 290.) In 2014, the Ninth Circuit affirmed Plaintiff’s 16 conviction. United States v. Quiel, 595 F. App’x 692 (9th Cir. Dec. 19, 2014), cert. denied, 17 575 U.S. 1011 (2015). Plaintiff’s subsequent efforts to vacate his sentence and obtain a 18 new trial have proven unsuccessful. See United States v. Kerr, No. 11-cr-02385-JAT, 2015 19 WL 4275183 (D. Ariz. July 15, 2015) (denying motion for new trial), aff’d, 709 F. App’x 20 431(9th Cir. Sept. 27, 2017); Quiel v. United States, No. 11-cr-02385-JAT-2, 2017 WL 21 4803823 (D. Ariz. Oct. 25, 2017) (denying motion to vacate under 28 U.S.C. § 2255), aff’d, 22 No. 17-17540, 2018 WL 11448309, (9th Cir. Dec. 21, 2018). 23 In 2021, after receiving authorization from the IRS, the Department of Justice filed 24 a civil suit against Plaintiff seeking to reduce to judgment FBAR penalties assessed against 25 him. United States v. Quiel, No. 21-cv-00094-GMS (D. Ariz.) (Doc. 1). In January 2024, 26 a jury found in favor of Plaintiff, so the complaint and action were dismissed. Id. (Doc. 27 129). Post-trial motions are pending. Id. (Doc. 140). 28 In the instant civil damages suit, Plaintiff is suing the United States, Rusch (the 1 attorney who allegedly stole his identity), Edelstein and Stockwell (the prosecutors in his 2 criminal case), and Bradley (the IRS agent who testified against Plaintiff in his criminal 3 trial). Plaintiff alleges RICO violations4 (Counts I and II), malicious prosecution (Count 4 III), wrongful institution of civil process (Count IV), and tortious interference with 5 business relationships (Count V) against Defendants. 6 II. Motion to Dismiss by the United States 7 The United States argues that sovereign immunity bars all five claims against it and 8 so they should be dismissed pursuant to Federal Rule of Civil Procedure 12(b)(1). (Doc. 9 26). The Court agrees. 10 Sovereign immunity goes to the Court’s subject matter jurisdiction. United States v. 11 Sherwood, 312 U.S. 584

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Quiel v. United States of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/quiel-v-united-states-of-america-azd-2024.