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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 AMSHEL ROTHSCHILD EL, CASE NO. 2:25-cv-01685-LK 11 Plaintiff, ORDER DISMISSING 12 v. COMPLAINT 13 CASCADE VIEW DRIVE LLC, et al., 14 Defendants. 15
16 This matter comes before the Court sua sponte and on pro se Plaintiff Amshel Rothschild 17 El’s Motion to Reinstate Original Complaint, Dkt. No. 14, and Motion for Judicial Notice, Dkt. 18 No. 13. On September 2, 2025, pro se Plaintiff Amshel Rothschild El filed a motion to proceed in 19 forma pauperis (“IFP”), Dkt. No. 1, and a proposed complaint seeking to quiet title to property 20 located in King County, Washington, as well as various other forms of relief against Defendants 21 Cascade View Drive LLC, Mortgage Electronic Registration Systems, Deutsche Bank Trust 22 Company Americas, Lina Fronda (Bank of America NA), and “All Persons or Entities Claiming 23 Any Interest in the Subject Property[.]” Dkt. No. 1-1 at 1, 3–4, 6–7. On September 3, 2025, United 24 States Magistrate Judge Michelle L. Peterson granted Mr. Rothschild El’s IFP application but 1 recommended that his complaint be reviewed under 28 U.S.C. § 1915(e)(2)(B) prior to the issuance 2 of summonses. Dkt. No. 3 at 1. On September 24, 2025, Mr. Rothschild El filed an amended 3 complaint. Dkt. No. 12. Six days later, he moved to reinstate his original complaint. Dkt. No. 14. 4 The Court must dismiss a case when the plaintiff is proceeding IFP “at any time” if it
5 determines that the complaint is frivolous, fails to state a claim on which relief may be granted, or 6 seeks monetary relief against a defendant who is immune from such relief. 28 U.S.C. § 7 1915(e)(2)(B). The standard for determining whether a plaintiff has failed to state a claim under 8 Section 1915(e) is the same as the standard applied under Federal Rule of Civil Procedure 12(b)(6). 9 Barren v. Harrington, 152 F.3d 1193, 1194 (9th Cir. 1998). Dismissal under Rule 12(b)(6) may 10 be based on either the lack of a cognizable legal theory or the absence of sufficient facts alleged 11 under a cognizable legal theory. Shroyer v. New Cingular Wireless Servs., Inc., 622 F.3d 1035, 12 1041 (9th Cir. 2010). 13 Mr. Rothschild El’s complaint asserts that he is “a Moorish American private citizen” and 14 “rightful heir of the Moabites” whose alleged interest in certain “subject property” “predates any
15 fraudulent sale or mortgage.” Id. at 3. The complaint is supported by a document titled “Owner’s 16 Aboriginal Title to Allodium,” issued under the alleged authority of the “Moorish National 17 Republic Federal Government[;] Moorish Divine and National Movement of the World[;] 18 Northwest Amexem/Northwest Africa/ North America/ ‘The North Gate’[;] Temple of the Sun 19 And Moon[;] Societas Republicae Ea Al Maurikano[;] The True and De jure Natural Peoples heirs 20 of the Land”—and other similar documents. Dkt. No. 4 at 19–20; see also id. at 13–14, 16–17, 22– 21 27, 29–35. Although the complaint references a number of federal statutes, id. at 5 (listing 42 22 23
24 1 U.S.C. § 1983; 18 U.S.C. § 1962; 15 U.S.C. § 1640; 12 U.S.C. § 2605), it fails to plead the elements 2 necessary to state a claim under any of these statutes.1 3 District courts may dismiss a complaint without leave to amend if “the allegation of other 4 facts consistent with the challenged pleading could not possibly cure the deficiency.” Schreiber
5 Distrib. Co. v. Serv-Well Furniture Co., 806 F.2d 1393, 1401 (9th Cir. 1986); see also Chappel v. 6 Lab. Corp. of Am., 232 F.3d 719, 725–26 (9th Cir. 2000) (explaining that a district court may deny 7 leave to amend when amendment would be futile). The Supreme Court has stated that “a finding 8 of factual frivolousness is appropriate when the facts alleged rise to the level of the irrational or 9 the wholly incredible[.]” Denton v. Hernandez, 504 U.S. 25, 32–33 (1992). 10 Like many other courts have found, complaints like Mr. Rothschild El’s rise to the level of 11 the irrational or the wholly incredible. The allegations in the complaint demonstrate that Mr. 12 Rothschild El is one of many individuals who claim to have “alleged ancestry in ancient Moors 13 (and/or on their alleged or actual adhesion to Moorish religious convictions)” in order to “initiat[e] 14 frivolous legal actions” on the basis of “their self-granted ‘Moorish citizenship’ and from their
15 correspondingly-produced homemade ‘Moorish’ documents[.]” Bey v. Stumpf, 825 F. Supp. 2d 16 537, 542 (D.N.J. 2011); see also id. at 539–43. For example, one of Mr. Rothschild El’s documents 17 proclaims the following: 18 Being a Moorish American, I am a Noble freeholder Original Indigenous Autochthonous Moor /Muur of the organic Americas - the Land. By Consanguine 19 Unity I am the descendant of the ancient Moabite Fore-Mothers and Fore-Fathers. My pledge of National, Political, and Spiritual allegiance is to my Moabite / 20
1 Under 42 U.S.C. § 1983, a plaintiff must allege (1) that a right secured by the Constitution or laws of the United 21 States was violated, and (2) that the alleged violation was committed by a person acting under the color of state law, West v. Atkins, 487 U.S. 42, 48 (1988), but even assuming that Mr. Rothschild El adequately alleged a constitutional 22 violation, he has not shown that any of the Defendants acted under color of state law. Mr. Rothschild El pleads no facts pertaining to any of the required elements of a cause of action under any subsection of 18 U.S.C. § 1962. See 23 generally Dkt. No. 4. Finally, Mr. Rothschild El has not stated a claim under either the Truth in Lending Act, 15 U.S.C. § 1640, et seq., or the Real Estate Settlement Procedures Act, 12 U.S.C. § 2605, et seq., because his complaint fails to provide enough detail for the Court to determine which provisions of these statutes have allegedly been 24 violated, or by whom. 1 Moorish Nation - being the Archaic Aboriginals / Indigenes of Amexem (the Americas) and stand squarely affirmed upon our Divine Oath to the ‘Five Points of 2 Light’ - Love, Truth, Peace, Freedom, and Justice.
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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 AMSHEL ROTHSCHILD EL, CASE NO. 2:25-cv-01685-LK 11 Plaintiff, ORDER DISMISSING 12 v. COMPLAINT 13 CASCADE VIEW DRIVE LLC, et al., 14 Defendants. 15
16 This matter comes before the Court sua sponte and on pro se Plaintiff Amshel Rothschild 17 El’s Motion to Reinstate Original Complaint, Dkt. No. 14, and Motion for Judicial Notice, Dkt. 18 No. 13. On September 2, 2025, pro se Plaintiff Amshel Rothschild El filed a motion to proceed in 19 forma pauperis (“IFP”), Dkt. No. 1, and a proposed complaint seeking to quiet title to property 20 located in King County, Washington, as well as various other forms of relief against Defendants 21 Cascade View Drive LLC, Mortgage Electronic Registration Systems, Deutsche Bank Trust 22 Company Americas, Lina Fronda (Bank of America NA), and “All Persons or Entities Claiming 23 Any Interest in the Subject Property[.]” Dkt. No. 1-1 at 1, 3–4, 6–7. On September 3, 2025, United 24 States Magistrate Judge Michelle L. Peterson granted Mr. Rothschild El’s IFP application but 1 recommended that his complaint be reviewed under 28 U.S.C. § 1915(e)(2)(B) prior to the issuance 2 of summonses. Dkt. No. 3 at 1. On September 24, 2025, Mr. Rothschild El filed an amended 3 complaint. Dkt. No. 12. Six days later, he moved to reinstate his original complaint. Dkt. No. 14. 4 The Court must dismiss a case when the plaintiff is proceeding IFP “at any time” if it
5 determines that the complaint is frivolous, fails to state a claim on which relief may be granted, or 6 seeks monetary relief against a defendant who is immune from such relief. 28 U.S.C. § 7 1915(e)(2)(B). The standard for determining whether a plaintiff has failed to state a claim under 8 Section 1915(e) is the same as the standard applied under Federal Rule of Civil Procedure 12(b)(6). 9 Barren v. Harrington, 152 F.3d 1193, 1194 (9th Cir. 1998). Dismissal under Rule 12(b)(6) may 10 be based on either the lack of a cognizable legal theory or the absence of sufficient facts alleged 11 under a cognizable legal theory. Shroyer v. New Cingular Wireless Servs., Inc., 622 F.3d 1035, 12 1041 (9th Cir. 2010). 13 Mr. Rothschild El’s complaint asserts that he is “a Moorish American private citizen” and 14 “rightful heir of the Moabites” whose alleged interest in certain “subject property” “predates any
15 fraudulent sale or mortgage.” Id. at 3. The complaint is supported by a document titled “Owner’s 16 Aboriginal Title to Allodium,” issued under the alleged authority of the “Moorish National 17 Republic Federal Government[;] Moorish Divine and National Movement of the World[;] 18 Northwest Amexem/Northwest Africa/ North America/ ‘The North Gate’[;] Temple of the Sun 19 And Moon[;] Societas Republicae Ea Al Maurikano[;] The True and De jure Natural Peoples heirs 20 of the Land”—and other similar documents. Dkt. No. 4 at 19–20; see also id. at 13–14, 16–17, 22– 21 27, 29–35. Although the complaint references a number of federal statutes, id. at 5 (listing 42 22 23
24 1 U.S.C. § 1983; 18 U.S.C. § 1962; 15 U.S.C. § 1640; 12 U.S.C. § 2605), it fails to plead the elements 2 necessary to state a claim under any of these statutes.1 3 District courts may dismiss a complaint without leave to amend if “the allegation of other 4 facts consistent with the challenged pleading could not possibly cure the deficiency.” Schreiber
5 Distrib. Co. v. Serv-Well Furniture Co., 806 F.2d 1393, 1401 (9th Cir. 1986); see also Chappel v. 6 Lab. Corp. of Am., 232 F.3d 719, 725–26 (9th Cir. 2000) (explaining that a district court may deny 7 leave to amend when amendment would be futile). The Supreme Court has stated that “a finding 8 of factual frivolousness is appropriate when the facts alleged rise to the level of the irrational or 9 the wholly incredible[.]” Denton v. Hernandez, 504 U.S. 25, 32–33 (1992). 10 Like many other courts have found, complaints like Mr. Rothschild El’s rise to the level of 11 the irrational or the wholly incredible. The allegations in the complaint demonstrate that Mr. 12 Rothschild El is one of many individuals who claim to have “alleged ancestry in ancient Moors 13 (and/or on their alleged or actual adhesion to Moorish religious convictions)” in order to “initiat[e] 14 frivolous legal actions” on the basis of “their self-granted ‘Moorish citizenship’ and from their
15 correspondingly-produced homemade ‘Moorish’ documents[.]” Bey v. Stumpf, 825 F. Supp. 2d 16 537, 542 (D.N.J. 2011); see also id. at 539–43. For example, one of Mr. Rothschild El’s documents 17 proclaims the following: 18 Being a Moorish American, I am a Noble freeholder Original Indigenous Autochthonous Moor /Muur of the organic Americas - the Land. By Consanguine 19 Unity I am the descendant of the ancient Moabite Fore-Mothers and Fore-Fathers. My pledge of National, Political, and Spiritual allegiance is to my Moabite / 20
1 Under 42 U.S.C. § 1983, a plaintiff must allege (1) that a right secured by the Constitution or laws of the United 21 States was violated, and (2) that the alleged violation was committed by a person acting under the color of state law, West v. Atkins, 487 U.S. 42, 48 (1988), but even assuming that Mr. Rothschild El adequately alleged a constitutional 22 violation, he has not shown that any of the Defendants acted under color of state law. Mr. Rothschild El pleads no facts pertaining to any of the required elements of a cause of action under any subsection of 18 U.S.C. § 1962. See 23 generally Dkt. No. 4. Finally, Mr. Rothschild El has not stated a claim under either the Truth in Lending Act, 15 U.S.C. § 1640, et seq., or the Real Estate Settlement Procedures Act, 12 U.S.C. § 2605, et seq., because his complaint fails to provide enough detail for the Court to determine which provisions of these statutes have allegedly been 24 violated, or by whom. 1 Moorish Nation - being the Archaic Aboriginals / Indigenes of Amexem (the Americas) and stand squarely affirmed upon our Divine Oath to the ‘Five Points of 2 Light’ - Love, Truth, Peace, Freedom, and Justice. I am by Birthright Heritage, and Primogeniture, the living Beneficiary, Heir, Jus sanguinis and Jus soli (by right of 3 soil) of the extreme far west Al Moroccan (American) Continents - Land of the Moors Territoria, North America, South America; Central America; including the 4 Adjoining Atlantis Islands (Americana / Ameru / Al Moroc)[.] 5 Dkt. No. 4 at 26. It is on this basis and other similar bases that he “make[s] adverse claim of 6 aboriginal title to [his] ancestral estate in reversion[.]” Id. at 33 (“This sacred property . . . has been 7 held in trust by Nature and the Great Mother,” and “[i]ts current structural improvements . . . do 8 not sever nor extinguish the birthright title held by Moorish American heirs.”). 9 Mr. Rothschild El has made two attempts to plead a viable complaint, and nothing about 10 the amended complaint2 or his briefing3 suggests that he is willing to plead the facts necessary to 11 show standing, or able to plead facts to state any plausible claim. Based on Mr. Rothschild El’s 12 fantastical allegations, the Court finds that his complaint is factually frivolous and that the defects 13 described above make leave to amend futile. Thus, as many other courts have done, this Court 14 denies leave to amend. See, e.g., Pernell El v. Wells Fargo Bank, No. CV2103137ABKESX, 2021 15 WL 4126915, at *3 (C.D. Cal. Sept. 3, 2021); Draper v. Round Hill Pac. Mgmt. LLC, No. 16 8:19CV203, 2020 WL 1677148, at *2 (D. Neb. Apr. 6, 2020); Bey v. Saucedo, No. 17 219CV2113TLNDBPS, 2020 WL 1640000, at *3 (E.D. Cal. Apr. 2, 2020), report and 18
19 2 See, e.g., Dkt. No. 12 at 1–2 (Mr. Rothschild El “asserts standing as the Moorish American heir, protected under the Treaty of Peace and Friendship (1787, reaffirmed 1836), invoking Article I, Section 10 of the U.S. Constitution, and the equity maxims that prohibit fraud and birthright theft,” alleges that Defendants’ “fraudulent conveyances stripped 20 equity and converted ancestral lands into debt pledges (mortgages), contrary to allodial title and constitutional protections,” and asks the Court to “[r]ecognize Plaintiff’s allodial title as superior to any claims by Defendants”). 21 3 See, e.g., Dkt. No. 5 at 1 (“Writ of Abatement in Equity” declaring that Mr. Rothschild El, “sui juris Moorish American, heir by blood and treaty, appearing in propria persona and not submitting to corporate jurisdiction, who by 22 this verified Affidavit and Writ of Abatement does place on the record the fraud of Caucasian Europeans masquerading as ‘Americans,’ demands abatement of all colorable proceedings, and seeks equitable relief, subrogation, and 23 injunction”); Dkt. No. 10 at 2 (“Affidavit & Judicial Notice of Fraudulent Status Correction” stating that “[t]he Treaty of Peace and Friendship . . . establishes recognition of the Moors . . . as the indigenous sovereigns of this land” and “[n]on-indigenous persons attempting to assume Moorish or treaty-based standing commit fraud and 24 misrepresentation against the heirs and the treaty itself”). 1 recommendation adopted, No. 2:19-CV-2113-TLN-DB, 2020 WL 3840774 (E.D. Cal. July 8, 2 2020). 3 The Court GRANTS Mr. Rothschild El’s Motion to Reinstate Original Complaint, Dkt. 4 No. 14, DISMISSES the operative complaint without leave to amend, Dkt. No. 4, and DENIES as
5 moot his Motion for Judicial Notice, Dkt. No. 13.4 The Clerk is directed to close this case. 6 Dated this 8th day of October, 2025. 7 A 8 Lauren King United States District Judge 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
4 Because docket entries 5, 6, 8, 9, and 10 do not fit into any category of acceptable filings permitted by the Federal 24 and Local Rules, the Court STRIKES them from the record.