“[F]rivolous complaints are subject to dismissal pursuant to the inherent authority of the court, even when the filing fee has been paid.”
How later courts described this case
- “[F]rivolous complaints are subject to dismissal pursuant to the inherent authority of the court, even when the filing fee has been paid.”
Written by the judges who cited it.
The opinion
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF NORTH CAROLINA
CHARLOTTE DIVISION
3:26-CV-00109-MEO-DCK
JARIN M. WRAY, )
)
Plaintiff, )
)
v. ) MEMORANDUM & ORDER
)
NBA PROPERTIES INC AND NFL )
PROPERTIES LLC, )
)
Defendants. )
)
THIS MATTER is before the Court on its own motion. For the reasons explained below,
Plaintiff’s Complaint is DISMISSED and Plaintiff is directed to SHOW CAUSE within fourteen
(14) days of this Order why this Court should not impose a pre-filing review system on any further
filings by Plaintiff in the Western District of North Carolina.
I. DISCUSSION
A. Initial Review
Plaintiff Jarin M. Wray, proceeding pro se, filed a short complaint comprising of a single
substantive paragraph that states as follows:
The NFL and NBA engaged in fraud schemes with China. The NBA
approved the sale of Boston Celtics for $6.1B and Lakers for $10B,
with both having heavy China linked entities. NFL stadiums and
privacy policies from the Dallas Cowboys ($13.1B) and New
England Patriots ($9.7B) also link back to heavy China entities.
These actions make a future purchase of a team difficult to achieve,
increase the business power of the league wide decisions, endangers
the security of the U.S. and our people, funds China directed
activities, and fosters an unethical business environment as
enforcing the law requires all business leaders to fully obey the law.
(Doc. No. 1 at 4). In his complaint, Plaintiff seeks the following relief:
Transfer of ownership of the Dallas Cowboys (before 2026
offseason) and Boston Celtics to Jarin Wray. Transfer ownership of
the New England Patriots to Tom Brady. Lakers to find new
ownership. Business review of the NFL and NBA’s legal entities,
governing body, and corporate policies. $100M payment of the
American Heart Association, the National Kidney Foundation, and
the State of North Carolina. *No criminal prosecution, this
settlement/case is to never be criminally charged or prosecuted, if
such action occurs, immediately reject the case, dismiss the case, or
grant a Presidential pardon without objection – U.S. systems failed
across the board over decades. This is a “onetime” educational fix,
work with the U.S. to make positive change in America for those
you’ve impacted, prove you can make a positive impact, be better in
real life to real people, future criminal actions can be linked back to
this settlement/case.* Dr. Jarin M. Wray, DBA.
Spread the word, we have real lives to touch, we don’t need legal
situations. Please stop these actions.
Id. at 4–5.
Although Plaintiff is not proceeding in forma pauperis, this action is still subject to initial
review pursuant to the inherent authority of the court to ensure that a plaintiff has standing, that
federal jurisdiction exists, and that the case is not frivolous. “It is well established that a court has
broad inherent power sua sponte to dismiss an action, or part of an action, which is frivolous,
vexatious, or brought in bad faith.” See Brown v. Maynard, No. CIV.A. L-11-619, 2011 WL
883917, at *1 (D. Md. Mar. 11, 2011); Ross v. Baron, 493 F. App’x 405, 406 (4th Cir. 2012)
(“[F]rivolous complaints are subject to dismissal pursuant to the inherent authority of the court,
even when the filing fee has been paid.”).
“A document filed pro se is to be liberally construed . . . and a pro se complaint, however
inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by
lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (citation modified). Nevertheless, the court
cannot ignore a clear failure to allege facts that set forth a cognizable claim. See Weller v. Dep’t
of Soc. Servs., 901 F.2d 387, 390–91 (4th Cir. 1990).
Here, Plaintiff purports to bring causes of action against Defendants for bank fraud under
18 U.S.C. § 1344, major fraud against the United States under 18 U.S.C. § 1031, laundering of
monetary instruments under 18 U.S.C. § 1956, “Antitrust,” and “China Owned/Shell Companies.”
(Doc. No. 1 at 3). Plaintiff cannot proceed in a private action for the purported violations of the
federal criminal code under Title 18. See, e.g., Holmes v. MBNA Am. Bank, N.A., No. 5:05-CV-
16, 2007 WL 952017, at *1 (W.D.N.C. Mar. 27, 2007) (“18 U.S.C. § 1344 is a criminal statute
and provides no private right of action”); Bell v. S.C. State Hous. Fin. & Dev. Auth., No. CV 3:24-
6493-SAL-SVH, 2024 WL 5240590, at *3 (D.S.C. Nov. 20, 2024), report and recommendation
adopted, No. 3:24-CV-6493-SAL, 2024 WL 5239865 (D.S.C. Dec. 27, 2024) (finding no private
right of action under 18 U.S.C. § 1956).1 Moreover, Plaintiff has not alleged any facts that
otherwise state a legal claim for which Plaintiff is entitled to relief. Thus, Plaintiff has not shown
that this Court has subject matter jurisdiction in this matter. For these reasons, Plaintiff’s action
must be dismissed.
B. Pre-Filing Review
A pre-filing review system is not a sanction the Court imposes lightly. Courts “should not
in any way limit a litigant’s access to the courts absent exigent circumstances, such as a litigant’s
continuous abuse of the judicial process by filing meritless and repetitive actions.” Cromer v. Kraft
Foods N. Am., Inc., 390 F.3d 812, 817-18 (4th Cir. 2004) (internal quotation marks and citation
omitted). “In determining whether a prefiling injunction is substantively warranted, a court must
weigh all the relevant circumstances, including (1) the party’s history of litigation, in particular
1 The Court recognizes that 18 U.S.C. § 1031(h) provides a private right of action to employees
who are “discharged, demoted, suspended, threatened, harassed, or in any other manner
discriminated against” because of lawful acts done by an employee “in furtherance of a [criminal]
prosecution.” Plaintiff has not alleged any facts that suggest Plaintiff meets those statutory
requirements.
whether he has filed vexatious, harassing, or duplicative lawsuits; (2) whether the party had a good
faith basis for pursuing the litigation, or simply intended to harass; (3) the extent of the burden on
the courts and other parties resulting from the party’s filings; and (4) the adequacy of alternative
sanctions.” Id. If a court determines that a “litigant’s abusive conduct merits a prefiling injunction,
the judge must ensure that the injunction is narrowly tailored to fit the specific circumstances at
issue.” Id.
Applying these factors to Plaintiff, it appears that the imposition of a pre-filing review is
warranted. Plaintiff has filed multiple actions that were dismissed by other courts in this district
because Plaintiff failed to allege federal claims.2 Despite being explicitly “cautioned against
repeatedly filing frivolous or improper actions” multiple times, Plaintiff has continued to pursue
litigation in this district without a good faith basis. See Order, Wray v. 47th Trump Admin. et al,
No. 3:25-CV-00884-FDW-SCR, (Doc. No. 13 at 6) (W.D.N.C. Jan. 15, 2026); see also Order,
Wray v. MQMF Charlotte SouthPark LLC et al., No. 3:26-cv-00029-MOC-DCK (Doc. No. 2 at
3). Plaintiff’s frivolous filings are also highly burdensome on the Court, causing the Court to
expend considerable time and judicial resources in attempting to interpret and address them. In
light of these circumstances, it appears Plaintiff will continue this behavior if not subjected to a
pre-filing review system.
“Before imposing a pre-filing limitation, the Court must offer a litigant the opportunity to
explain why the Court should not impose such a pre-filing review system upon all future filings
from him.” Simpson v. Jennings, No. 1:25-CV-00364-MR-WCM, 2025 WL 3215949, at *3
(W.D.N.C. Nov. 18, 2025) (citing Vandyke v. Francis, No. 1:12-CV-128-RJC, 2012 WL 2576746,
2 Wray v. MQMF Charlotte SouthPark LLC et al, 3:25-cv-00864-MOC-SCR (WDNC); Wray v.
RTX Corporation, No. 3:25-cv-00656-MOC-SCR (WDNC); Wray v. Universal Music Group,
Inc. et al, No. 3:25-cv-00866-MOC-DCK WDNC); Wray v. MQMF Charlotte SouthPark LLC et
al, 3:26-cv-00029-MOC-DCK (WDNC).
at *3 (W.D.N.C. July 3, 2012)). If Plaintiff fails to adequately explain why such a system should
not be imposed, the Court may enter an order directing documents submitted by Plaintiff be
administratively pre-screened for content. /d. Pursuant to such review, any proposed filings not
made in good faith or which lack merit will be returned to Plaintiff without further explanation.
Id. This review system “will allow Plaintiff to have access to the [cJourts for his legitimate
concerns, but will prevent him from usurping the Court’s resources with his baseless submissions.”
Id.
Plaintiff is, therefore, DIRECTED to SHOW CAUSE within fourteen (14) days of the
entry of this Order, explaining why he believes the above-described pre-filing review system
should not be imposed. Plaintiffs filing shall not exceed three (3) pages. Plaintiff is expressly
warned that if he fails to fully comply with this directive, the Court may impose the pre-filing
review system described above.
Il. CONCLUSION
IT IS, THEREFORE, ORDERED that:
1. Plaintiff’s Complaint (Doc. No. 1) is DISMISSED WITHOUT PREJUDICE;
2. Plaintiff is DIRECTED to SHOW CAUSE within fourteen (14) days of the entry
of this Order why a pre-filing review system should not be imposed; and
3. The Clerk is directed to close this matter in accordance with this Order.
SO ORDERED.
Signed: April 7, 2026
Matthew E. Orso Wy
United States District Judge ey