Opinion

Wray

Court
District Court, W.D. North Carolina
Filed
Apr 8, 2026
Cited by
0 cases
Authority
More cited than 40.1%

“[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

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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