Magistrate Judge Recommends Dismissal of David C. White’s Crypto Dispute Against Coin Hub
On Monday, May 4, 2026, U.S. Magistrate Judge Alison S. Bachus for the United States District Court for the District of Arizona recommended that a complaint filed by David C. White be dismissed for lack of subject-matter jurisdiction.
The case, David C. White v. Coin Hub, et al., was referred to the magistrate judge for review. Bachus said federal courts may hear only those cases the Constitution and Congress have authorized, including matters presenting a federal question or certain other categories, such as cases involving the United States as a party or diversity jurisdiction. The magistrate judge emphasized that federal courts must independently verify their jurisdiction, even if the parties do not challenge it.
Bachus’s report said White’s complaint asserted “federal question jurisdiction,” but that the complaint did not identify the specific federal statutes, treaties, or constitutional provisions at issue. The magistrate judge also found the complaint’s statement of claim did not clearly set out a federal basis for the court to exercise jurisdiction.
Instead, Bachus described the allegations as centering on an “investment account” with a cryptocurrency platform and a claim that White was owed funds by the named defendants, without clearly explaining the basis for liability for each defendant or tying the dispute to a particular federal legal theory on the face of the pleading.
The report also referenced a document attached to the complaint described as a “commitment letter.” The magistrate judge said the letter included language requiring disputes to be handled through negotiation and, if negotiation fails, submitted to the District of Arizona for adjudication or arbitration. Bachus concluded that contractual language of that kind does not, by itself, create subject-matter jurisdiction, because jurisdiction must be authorized by the Constitution and statute.
Because the complaint did not properly establish federal jurisdiction, Bachus recommended dismissal without prejudice, allowing the plaintiff an opportunity to amend. The magistrate judge also stated that when the complaint is read liberally, White might be able to plausibly invoke jurisdiction with a properly supported amended filing.
Bachus recommended that the district court dismiss the complaint and allow White 14 days from the filing date of the court’s order to submit an amended complaint. The report directed White to comply with Rule 8(a) of the Federal Rules of Civil Procedure, to state all claims he intends to bring, and to include the jurisdictional basis and supporting allegations for each, without incorporating any part of the original complaint by reference.
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