Consumer complaint received 2025-05-03 00:00:00
Product: Checking or savings account — Checking account
Issue: Managing an account — Problem making or receiving payments
Company: Comerica
State: NV

Complaint narrative:
XXXX XXXX  DISTRICT COURT [ District ] Case No. [ Insert Case Number ] XXXX XXXX XXXX, Plaintiff v. [ Defendant ( XXXX ) ], Defendant ( s ) COMPLAINT FOR VIOLATION OF CIVIL RIGHTS I. INTRODUCTION 1. This action arises under 42 U.S.C. 1983, seeking redress for violations of Plaintiffs constitutional rights, including the First Amendment right to the free exercise of religion and the Fifth Amendment rights to due process and equal protection.

2. Plaintiff alleges that the actions of the Defendant ( s ), including refusal to process Plaintiffs birth registration and denial of SSDI benefits, have directly violated Plaintiffs civil rights under XXXX of state law, as these actions interfere with Plaintiffs right to exercise their religious beliefs freely, as well as creating impossibilities in commerce violating the hobbs act with third parties not needed, and hindering interstate commerce, i wont be able to keep a home and pay bills. 

3. XXXX XXXX Scriptures : - XXXX XXXX ( XXXX XXXX XXXX : 'ThoXXXX shalt not make unto thee any graven image, nor any likeness of anything that is in the heaven above, or in the earth beneath, or in the waters beneath the earth. Thou shalt not bow down thyself to them, nor serve them : for I the XXXX thy XXXX am a jealous XXXX. ' - XXXX XXXX ( XXXX XXXX ) : 'They say unto him, XXXX XXXX. Then saith he unto them, Render therefore unto XXXX the things which are XXXX 's ; and unto XXXX the things that are XXXX 's. ' - XXXX XXXX ( XXXX XXXX ) : 'One man esteemeth one day above another : another esteemeth every day alike. Let every man be fully persuaded in his own mind. ' These scriptures affirm the Plaintiffs religious objection to any form of graven image or idolatry, including government-issued identification, which the Plaintiff can not accept in adherence to their faith. 
II. JURISDICTION AND VENUE 1. This Court has jurisdiction over the claims raised under 42 U.S.C. 1983 pursuant to 28 U.S.C. 1331, as this case involves the violation of federal civil rights.

2. Venue is proper in this district under 28 U.S.C. 1391 ( b ) because the events giving rise to this action occurred within this district and Defendant ( s ) are located in this district.

III. PARTIES 5. Plaintiff, XXXX XXXX XXXX, is a resident of XXXX XXXX XXXX, XXXX, Nevada XXXX. Plaintiff is an XXXX who follows the tenets of their faith, which prohibit the use of graven images and idolatry, including government-issued photo identification. 

6. Defendant ( s ), [ State Agency/Corporation Name ], are governmental and corporate entities, under color of law, responsible for processing federal and state benefits, including SSDI and issuance of identification documents. 
IV. FACTUAL ALLEGATIONS 7. Plaintiff is an XXXX and adheres to religious beliefs prohibiting the use of photo identification. 

8. Plaintiff applied for Social Security Disability Insurance ( SSDI ) benefits and submitted a delayed birth registration as part of their application process.

9. Defendant, [ State or Federal Agency ], refused to accept Plaintiffs delayed birth registration as a valid birth certificate, citing it as inadequate, even though Plaintiff is unable to provide traditional photo ID due to their religious beliefs.

10. As a result of Defendant 's refusal to process Plaintiffs claim, Plaintiff has been denied SSDI benefits, which are essential for Plaintiffs and their familys livelihood.

11. Defendants actions have caused Plaintiff significant harm, including emotional distress, financial hardship, and violation of Plaintiffs religious rights.

V. CLAIMS FOR RELIEF COUNT I : Violation of the Free Exercise Clause of the First Amendment 12. Plaintiff incorporates by reference the allegations in paragraphs 1 through 11.

13. Defendants refusal to accept Plaintiffs delayed birth registration as a valid birth certificate, in light of Plaintiffs religious beliefs, constitutes a violation of Plaintiffs First Amendment right to freely exercise religion.

14. Defendants actions have placed an undue burden on Plaintiffs ability to practice their faith and have denied Plaintiff benefits to which they are entitled based solely on religious beliefs. 

15. XXXX XXXX Scriptures : - XXXX XXXX ( XXXX XXXX ) : 'Ask, and it shall be given you ; seek, and ye shall find ; knock, and it shall be opened unto you. ' - XXXX XXXX ( XXXX XXXX ) : 'If any of you lack wisdom, let him ask of XXXX, that giveth to all men liberally, and upbraideth not ; and it shall be given him. ' These scriptures reinforce the Plaintiffs religious duty to seek fairness and justice, and to be granted the accommodation necessary to practice their faith without discrimination. 

16. Prayer for Relief : Plaintiff respectfully requests that this Court order Defendant ( s ) to grant SSDI benefits without requiring traditional forms of photo identification, as well as provide any other remedies the Court deems appropriate.

COUNT II : Violation of Due Process Under the Fifth Amendment 16. Plaintiff incorporates by reference the allegations in paragraphs 1 through 11.

17. The denial of SSDI benefits without allowing reasonable religious accommodations and failure to process Plaintiffs valid birth registration violates Plaintiffs Fifth Amendment due process rights.

18. Defendants refusal to recognize the validity of Plaintiffs delayed birth registration and subsequent denial of SSDI benefits is arbitrary and capricious, lacking proper procedure or justification, and denies Plaintiff access to essential benefits.

19. Maxims of Equity : - 'Equity will not suffer a wrong to be without a remedy. ' - 'Equity follows the law. ' - 'He who comes into equity must come with clean hands. ' These maxims assert that the Plaintiff is entitled to a remedy for the wrong done and that equity demands fair treatment regardless of arbitrary barriers such as government identification requirements.

20. Prayer for Relief : Plaintiff requests an order from the Court requiring Defendant ( s ) to process Plaintiffs SSDI claim and afford Plaintiff due process under the law.

COUNT III : Violation of Equal Protection Under the Fifth Amendment 20. Plaintiff incorporates by reference the allegations in paragraphs 1 through 11.

21. Defendants refusal to accept Plaintiffs delayed birth registration and denial of SSDI benefits based on religiously motivated objections constitutes discrimination in violation of Plaintiffs Fifth Amendment right to equal protection.

22. Defendants actions disproportionately affect individuals who hold similar religious beliefs and can not comply with standard identification procedures, violating Plaintiffs right to equal protection under the law.

23. Maxims of Equity : - 'Where there is equal justice, there is no discrimination. ' - 'Equity requires the equal application of the law. ' These maxims reinforce the principle that no person should be discriminated against or denied justice due to their religious beliefs.

24. Prayer for Relief : Plaintiff requests the Court to order Defendant ( s ) to cease discriminating based on religious beliefs and to afford Plaintiff the same legal rights and protections as any other SSDI applicant.

VI. PRAYER FOR RELIEF WHEREFORE, Plaintiff respectfully requests the following relief from the Court : 1. That the Court order Defendant ( s ) to process Plaintiffs SSDI application and grant the benefits without requiring photo ID, pursuant to Plaintiffs religious beliefs.

2. That the Court award Plaintiff all damages sustained as a result of Defendants unlawful actions, including compensatory damages for financial hardship, emotional distress, and other harms.

3. That the Court award Plaintiff punitive damages as appropriate to deter Defendant ( s ) from future constitutional violations.

4. That the Court order Defendant ( s ) to take all necessary steps to implement reasonable religious accommodations in the SSDI application process.

5. That the Court grant any other relief the Court deems just and proper.

VII. CONCLUSION Plaintiff requests this Court to consider the serious constitutional violations committed by Defendant ( s ), and to grant relief to prevent further harm and uphold Plaintiffs rights under the First, Fifth, and Fourteenth Amendments of the United States Constitution. 
Respectfully submitted, XXXX XXXX XXXX [ Your Contact Information ] Additional Legal Grounds and Violations In addition to the claims brought under 42 U.S.C. 1983, Plaintiff asserts further violations of federal and international law : 1. * * Hobbs Act Violations ( 18 U.S.C. 1951 ) : * * The refusal of government agencies and contracted service providers to accept lawful identity documentssuch as a delayed birth certificateconstitutes obstruction and extortion under XXXX of official right. These actions hinder access to Social Security Disability Insurance ( SSDI ) benefits and directly interfere with interstate commerce, as defined by the Hobbs Act.

2. * * Violation of International Banking and Human Rights Norms : * * Under international banking law, including the Basel Accords and Universal Declaration of Human Rights, Article 25, individuals have a right to security in the event of unemployment, XXXX, or other circumstances beyond their control. Interference with access to subsistence resources may also constitute a breach of financial accessibility norms and fiduciary duties.

3. * * Pertinent Federal Case Law : * * - * XXXX XXXX XXXX *, XXXX XXXX XXXX ( XXXX ) : Established that government benefits are a form of property requiring due process before termination. 
- * XXXX v. XXXX *, XXXX XXXX XXXX ( XXXX ) : Found that state action which burdens religious exercise must be justified by a compelling interest. 
- * XXXX v. XXXX XXXX XXXX XXXX XXXX *, XXXX XXXX XXXX ( XXXX ) : Affirmed religious accommodations under federal law. 
- * XXXX of Regents v. XXXX *, XXXX XXXX XXXX ( XXXX ) : Defined property interests in the context of public benefits. 
- * XXXX v. Ohio *, XXXX XXXX XXXX ( XXXX ) : Provided strong protections for freedom of expression, especially religious beliefs. 

These violations demonstrate systemic suppression of religious practice and discriminatory treatment in violation of clearly established federal law and international norms. The plaintiff seeks immediate injunctive relief and full restitution.

Company response to consumer: Closed with non-monetary relief