Rothfeld v. Trump

• Court: District Court, District of Columbia
• Decided: November 5, 2025
• Docket: Civil Action No. 2025-3815
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA _________________________________________ ) TZVI DOV ROTHFELD ) ) Plaintiff, ) ) v. ) Case No. 25-cv-03815 (APM) ) PRESIDENT OF THE UNITED STATES, ) MR. DONALD J. TRUMP AND ) THE UNITED STATES DEPARTMENT ) OF STATE, ) ) Defendants. ) _________________________________________ )

MEMORANDUM OPINION

Plaintiff Tzvi Dov Rothfeld, proceeding pro se, brings several claims against Defendants

President Donald J. Trump and the United States Department of State. Compl., ECF No. 1

[hereinafter Compl.], ¶¶ 6, 12. Because Plaintiff fails to raise a substantial federal question and

his claims are patently frivolous, the court sua sponte dismisses the Complaint and this action.

“[F]ederal courts are without power to entertain claims otherwise within their jurisdiction

if they are so attenuated and unsubstantial as to be absolutely devoid of merit” or “obviously

frivolous.” Hagans v. Lavine, 415 U.S. 528, 536–37 (1974) (internal quotation marks and citations

omitted); see also Tooley v. Napolitano, 586 F.3d 1006, 1009 (D.C. Cir. 2009) (“A complaint may

be dismissed on jurisdictional grounds when it ‘is patently insubstantial, presenting no federal

question suitable for decision.’” (internal quotation marks omitted) (quoting Best v. Kelly, 39 F.3d

328, 330 (D.C. Cir. 1994))). Claims are insubstantial and frivolous if they are “essentially

fictitious” because they advance, for example, “bizarre conspiracy theories.” Best, 39 F.3d at 330 (internal quotation marks omitted). In such cases, a district court may dismiss the case sua sponte.

See Lewis v. Bayh, 577 F. Supp. 2d 47, 54 (D.D.C. 2008).

Here, Plaintiff alleges a conspiracy to murder him to take his property. Compl. ¶ 9. The

alleged conspiracy began in 2024 when a person impersonating Plaintiff went to the United States

Embassy in Paris to obtain an emergency U.S. passport linked to Plaintiff. Id. ¶¶ 1, 4–5. The

person impersonating Plaintiff departed and “is apparently being held in a federal prison under the

designation ‘Prisoner X.’” Id. ¶ 7. Plaintiff alleges his life, the life of his “Guardian of Property

in New York,” and his property are in immediate danger. Id. ¶ 8. The “suspect seeks to extract a

will” from Plaintiff and “then murder [him], thereby taking all of [his] property from [his]

Guardian of Property in New York.” Id. ¶ 9. Ultimately, Plaintiff alleges that “all government

officials, including the President, were negligent in these actions, and that the President bears direct

responsibility for the conduct of any official acting in an official capacity on behalf of the United

States.” Id. ¶ 12. Plaintiff seeks compensatory damages in the amount of $5 million and punitive

damages in the amount of $26 million, along with relief related to issuance of passports. Id. ¶ 15.

The court is mindful that complaints filed by pro se litigants are held to less stringent

standards than those applied to formal pleadings drafted by lawyers. See Haines v. Kerner,

404 U.S. 519, 520 (1972). But Plaintiff’s claim is “patently insubstantial” and presents “no federal

2 question suitable for decision.” Best, 39 F.3d at 330 (citations omitted). Accordingly, the court

dismisses the Complaint and this action for lack of subject matter jurisdiction.

A separate final, appealable order accompanies this Memorandum Opinion.

Dated: November 5, 2025 Amit P. Mehta United States District Judge