Case Citation Appendix

Redemption schemes / Treasury accounts / birth-certificate bond / HJR-192-style discharge

Shipman v. Bank of America, N.A., No. 3:16-cv-772-RJC-DSC (W.D.N.C.) (self-created trust paper asserted to discharge a recorded deed of trust, and a decision to cite in both halves of its posture. The pro se complaint was styled an "Action for Trustee to Perform Under Terms of the Deed" and rested on a "Deed of Special Trust" by which the plaintiff purported to "terminate[] and disclaim[] any/all purported resident agency, public office, public trusteeship, and/or public Suretyship", defined the "Collateral" as her own name in its all-capitals form, and quit-claimed the property to "SCS Trustee" — while the deed of trust securing the note she had signed with her husband remained of record. The magistrate judge's Memorandum and Recommendation, 2017 WL 872651 (Mar. 3, 2017) (Cayer, M.J.), found that "[t]he Complaint comports with 'sovereign citizen' ideology" and held: "This claim is frivolous. A borrower cannot release herself from a deed of trust." POSTURE — a recommendation is not a judgment, and the district judge adopted it only in part. By order of Aug. 15, 2018 (Conrad, J.), the M&R was "ADOPTED in part": the claims against Bank of America were dismissed WITH PREJUDICE for failure to state a claim as recommended, but the claims against the Treasury defendants were dismissed WITHOUT prejudice for lack of subject-matter jurisdiction rather than for failure to state a claim. Cite the frivolousness holding to the adopted portion running against the bank; do not cite it for the disposition as to the federal defendants. ATTRIBUTION — the M&R's statement that courts have described sovereign-citizen claims as "frivolous, irrational [and] unintelligible" is itself a quotation of United States v. Staten, 2012 U.S. Dist. LEXIS 87556 (M.D. Pa. 2012), quoting United States v. Ornelas, 2010 U.S. Dist. LEXIS 119194 (S.D. Ala. 2010) — the phrase belongs to those decisions; this one is a quoting court, and a string cite that credits it here has shortened the chain.).

Johnson v. Freedom Mortgage Corp., Nos. 25-1940 through 25-1948 (4th Cir. Apr. 27, 2026) (Unpublished per curiam opinion — "Unpublished opinions are not binding precedent in this circuit"; persuasive authority only) (nine consolidated appeals, dismissals under 28 U.S.C. § 1915(e)(2)(B)(i) AFFIRMED. "Johnson filed nine substantially similar actions against eight private creditors and one municipal water utility"; in each she alleged that "she created a trust, assigned encumbered assets to that trust, and sent Defendants various documents purportedly discharging her financial obligations", then sued when they kept collecting. Held frivolous because "they rely on a sovereign citizen theory to avoid debt repayment". Note the SECOND, independent ground, which is the more portable one: "Johnson failed to demonstrate the existence of any lawful trust and that, even assuming a valid trust, Johnson could not proceed pro se on its behalf" — a pro se litigant cannot represent a trust, so the trust wrapper defeats itself procedurally before the ideology is reached.).

In re Fachini, 470 B.R. 638, 641–43 (Bankr. M.D. Ga. 2012) (Walker, B.J.) (redemption paper used OFFENSIVELY: a third party, Rogers, filed "an involuntary Chapter 7 petition against Denise Fachini" asserting a $10 million claim built entirely from redemption instruments — an "International Bill of Exchange" drawn on a "UCC CONTRACT TRUST ACCOUNT" at the Treasury, an "accepted for value" chargeback under HJR-192, a birth-certificate bond, and a UCC-3 recording the dishonour. Redemption theory here is a weapon aimed at a private individual, not a shield raised against a creditor. Held sua sponte that the supporting documents "only serve to undermine it by revealing it to be a sham" (641); the court names the doctrine — "known as redemption theory" (642) — and dismisses because the claim is founded on an instrument ruled illegitimate by multiple courts and "declared worthless by the Treasury Department", entertaining it being something that "would transform the ideal of due process into an instrument of chicanery" (643) — DISMISSED.).

Gravatt v. United States, 100 Fed. Cl. 279, 286 (2011) (Sweeney, J.) (Court of Federal Claims; a federal prisoner claimed the United States had been made trustee of an account created for his benefit. The opinion opens with a section headed "The Sovereign Citizen Movement" and supplies a definition courts have since reused: the plaintiff "adheres to the belief that even though he was born and resides in the United States, he is his own sovereign and is therefore not a United States citizen", and "This belief is the hallmark of the sovereign citizen movement". The court "dismisses plaintiffs complaint for lack of jurisdiction" and "further finds plaintiffs complaint to be frivolous"; on the birth-certificate and social-security-number-as-express-contract theory it held at 286 that "Such allegations are frivolous and cannot support the court's exercise of jurisdiction in this matter".).

Monroe v. Beard, 536 F.3d 198, 203 n.4 (3d Cir. 2008) (per curiam) (n.4 describes the "Redemptionist" theory as propounding "that a person has a split personality: a real person and a fictional person called the 'strawman'"; "Redemptionists claim that government has power only over the strawman and not over the live person, who remains free. Individuals can free themselves by filing UCC financing statements, thereby acquiring an interest in their strawman. Thereafter, the real person can demand that government officials pay enormous sums of money to use the strawman's name or, in the case of prisoners, to keep him in custody." The n.4 paragraph is definitional background from Cracking the Code and a prison-counsel declaration, not a merits holding that the theory is legally invalid; the holding is that Pennsylvania prison officials could confiscate UCC, redemption, and name-copyrighting materials as contraband because they facilitate fraudulent liens against officials).

Wood v. United States, 161 Fed. Cl. 30, 33–34 (Fed. Cl. 2022) (Court of Federal Claims rejected redemption-style monetary claim — "plaintiff relies on a legal fiction to support a monetary claim that has no basis in the laws of the United States"; court explained sovereign citizens "sometimes reference the Cestui Que Vie Act of 1666, or a 'cestui que vie' trust" and birth-certificate collateral theories).

Ammon v. United States, 142 Fed. Cl. 210, 214–20 (2019) (Court of Federal Claims — No. 18-1641C; case syllabus headnotes "Sovereign Citizen"; pro se prisoner sought ~$49.8M on the theory that issuance of his birth certificate and Social Security number formed a contract with the United States obligating compensation for civic duties — "paying taxes, voting, using his corporate name traded on the open market" — and that failure to redeem an alleged savings bond was both breach of contract and a Fifth Amendment taking; held such birth-certificate/SSN-as-contract and redemption claims "are frivolous and cannot serve as the basis for this Court's assertion of jurisdiction," citing Rivera that "neither a birth certificate nor a social security number evidence a contract on which a private party can sue the Government"; dismissed sua sponte with prejudice for lack of subject-matter jurisdiction under RCFC 12(h)(3); also noted 28 U.S.C. § 1500 duplicate-suit bar; appeal dismissed, No. 19-1759 (Fed. Cir. June 21, 2019)).

United States v. Hesser, 800 F.3d 1310, 1320–21 (11th Cir. 2015) (per curiam) (the 1099-OID false-refund mechanism, held on its own terms. Convictions on three counts of submitting false claims under 18 U.S.C. § 287 and one count of tax evasion under 26 U.S.C. § 7201 AFFIRMED; on sufficiency the court held "the evidence on the issue of falsity is not so paltry as to render Hesser's false-claims convictions manifestly unjust" at 1320. The disposition is split — "Of these challenges, only the last has merit" — and the RESTITUTION ORDER WAS VACATED AND REMANDED at 1315 for recalculation of the IRS's actual loss. SCOPE — this is not a characterisation of sovereign-citizen or redemption ideology and must never be cited as one. The court expressly refused to supply one: "We will not attempt to render coherent Hesser's tax theory, as it is not material to his appeal" (n.18) — the word "sovereign" appears once in the whole opinion, in that footnote, and only inside the title of a DOJ bulletin article cited for background; both appearances of "redemption" are the bond sense — the R in original issue discount — not the ideology. Offered here for the false-claims holding on 1099-OID filings, which is what Croteau, 819 F.3d at 1297–98 & 1301, cites it for.).

United States v. Croteau, 819 F.3d 1293, 1301, 1306–07 (11th Cir. 2016) (affirming conviction on ten counts under 18 U.S.C. § 287 and one count under 26 U.S.C. § 7212(a) where defendant filed fictitious 1099-OID forms claiming refunds and recorded a "Notice of Lien, Diplomatic Immunity and Identity Bond on Land" and a "Private Discharging and Indemnity Bond" for $300 million against IRS officials, signing as "Ronald-Francis of the family Croteau"; at 1301 the court describes the Little Tribe of the Pembina Nation as "a tax protester and sovereign citizen group" whose members paid roughly $700 for identification cards stating they were "exempt from paying taxes"; SCOPE — the court decided only sufficiency of the evidence and reasonableness of the sentence, and Croteau never asserted tribal status or immunity, so this is a holding on neither; at 1306–07 the ideology cuts AGAINST the defendant — his association with the group "undercuts the suggestion that Croteau’s behavior was due to a genuine psychological condition," defeating his delusional-disorder defense).

United States v. Allen, No. 1:25-cv-00118 (W.D. Mich. June 15, 2026) (court granted summary judgment piercing a trust ('Golden Assets Settlement Trust') as defendant's alter ego after she filed a fraudulent Form 1041 refund claim based on redemption-theory instruction from a sovereign-citizen-affiliated group; defendant held personally and jointly liable for resulting tax debt; the trust was real and capitalized, not merely asserted in correspondence).

Shephard v. Wells Fargo Bank, N.A., No. 2:25-cv-01885-APG-NJK (D. Nev. June 23, 2026) — birth certificate bond claiming $7.9M–$8.5M from Treasury Setoff Account dismissed with prejudice; "Without the United States" address notation flagged as sovereign citizen signifier; strawman theory called well-known scam. MacArthur-Brooks Estate v. Moreno, No. 24-cv-24273-RKA, ECF No. 29 (S.D. Fla. Jan. 3, 2025) (Altman, J.) (a $2.9 billion complaint premised on 'TACIT PROCURATION' — the theory that defendants' silence on a Commercial Affidavit and Contract and Security Agreement constituted admission of liability; Bill of Exchange and vapor money theory (UCC §§ 3-104, 3-603, Public Law 73-10) rejected as 'rightly and roundly pilloried'; $200 billion Master Discharge and Indemnity Bond purportedly held with the Federal Reserve. NOT A DISMISSAL. The document is titled "ORDER REMANDING CASE" and its mandate is "This action is REMANDED to the Eleventh Judicial Circuit in and for Miami-Dade County, Florida". The plaintiffs sued in STATE court and the DEFENDANTS removed; nine of the eleven federal counts rest on "federal criminal statutes that create no private right of action at all" and so cannot sustain jurisdiction, while "the remaining two federal-law counts are so frivolous and insubstantial that we don't think they raise a federal question" — insubstantiality as a test for JURISDICTION, not a merits ruling. "Since there's no true federal question before us, we remand this case to state court", and the court "can't and won't exercise supplemental jurisdiction over the remaining state-law counts". SCOPE — cite this for a federal court DECLINING JURISDICTION over sovereign-citizen paper, never as a merits dismissal of it: the claims returned to state court and no court has adjudicated them. The order also holds squarely on trust representation: "a nonlawyer trustee has no authority to represent a trust in court", so "All the Plaintiffs' filings are STRICKEN" as made by "non-lawyers with no authority to represent the Trust in federal court". It also imposes a pre-filing restriction — "We DIRECT the Clerk of Court to reject or decline to file all papers filed by Kevin Walker on behalf of any party other than himself" — and warns that "The Court will impose sanctions against MacArthur-Brooks and Walker if they continue to file frivolous documents").

Katrina Allen v. Blackbaud, Inc., No. W2025-01484-COA-R3-CV (Tenn. Ct. App. July 9, 2026) (Tennessee Court of Appeals — authored panel opinion; pending official reporter citation; first Tennessee appellate decision addressing sovereign-citizen/redemption theory in the civil context; affirmed dismissal of breach-of-contract claim grounded in redemptionist theory including durable power of attorney separating the "strawman" ALL-CAPS name from the real person, UCC negotiable-instrument/tender-of-payment language under Tenn. Code Ann. §§ 47-3-104, 47-3-505, 47-3-603(b), "Notice of Claim to Interest" demanding beneficiary/set-off status, and stamped Treasury-redemption notation on the underlying invoice; frivolous-appeal damages awarded under Tenn. Code Ann. § 27-1-122 — claims "utterly devoid of merit" and grounded in law "she has created"; Allen cites United States v. Cook, No. 3:18-CR-00019, 2019 WL 2721305 (E.D. Tenn. June 28, 2019) for general sovereign-citizen background).

Caren D. Enloe, Sovereign Citizens and the Raging War of Paper Terrorism, 78 Consumer Fin. L.Q. Rep. 250, 255–56 (2025) — secondary source (cited by Allen; defines strawman/redemptionist theory — 1933 gold-standard origin, birth-certificate strawman split, "exemption account" mechanics; not controlling authority).

Maule v. Capital One, N.A., No. 3:25-CV-417-TAV-DCP (E.D. Tenn. July 23, 2026) (Varlan, J.) (granting summary judgment to defendant; rejected pro se plaintiff's theory that a consumer credit application "generated a security interest" and formed a constructive trust with himself as trustee, imposing fiduciary duty on the creditor for "securitizing" the application without disclosure — a consumer-credit variant of the constructive-trust/administrator-trustee framing seen in Moore v. State; also rejected tender of a self-created "Bill of Exchange" as lawful payment and the argument under UCC § 3-505 that defendant's non-response to the tender constituted "tacit agreement" admitting liability; further rejected the Federal Reserve Act "lawful money" theory that Federal Reserve notes are not lawful tender and that the debt was thereby prepaid; collecting citations rejecting the Bill of Exchange theory, including Wilson v. Abound Credit Union, No. 3:24-cv-446, 2024 WL 5089568 (W.D. Ky. Dec. 12, 2024), Campbell v. Foursight Capital, LLC, No. 3:25-cv-22, 2025 WL 2172546 (S.D. Ohio July 31, 2025), Kennebrew v. PNC Bank, No. 1:25-cv-13, 2025 WL 801169 (E.D. Tenn. Mar. 13, 2025), and Bryant v. Washington Mut. Bank, 524 F. Supp. 2d 753 (W.D. Va. 2007)).

United States v. Kriemelmeyer, No. 3:07-cr-00052-bbc (W.D. Wis. Nov. 20, 2007) (Crabb, J.) (silence-as-consent / tacit-acquiescence theory rejected: defendant mailed affidavits carrying a written warning that the recipients' silence would constitute agreement, then argued the affidavits "stand as undisputed facts because the affidavits were never contested despite the written warning to the recipients that their silence would stand as consent to the factual declarations in the affidavits"; the court called this a "meritless position" and held "Defendant cites no law or rule that would support his position". This is the same theory as MacArthur-Brooks' TACIT PROCURATION claim and Maule's UCC § 3-505 "tacit agreement" claim, stated more plainly and by a court reaching it directly rather than in passing).

Raspaldo v. Wilmington Trust Co., No. 2:26-cv-03340-CFK (E.D. Pa. Aug. 28, 2026) (Kenney, J.) (ECF Nos. 7, 8) (Unpublished district-court opinion — persuasive authority only, not binding precedent; pending official reporter citation) (the "received at par" discharge variant, screened under 28 U.S.C. § 1915(e)(2)(B)(i) — a widow challenged a nonjudicial foreclosure on the theory that her late husband's $113,000 mortgage note was a "congressionally designated security" that the lender "received at par" under the Federal Reserve Act, which "extinguishes the underlying obligation" — pleaded together with the Emergency Banking Relief Act, the Restatement 3rd of Agency, the Restatement (2nd) of Contracts, the Uniform Commercial Code, and Federal Reserve Operating Circular No. 10 § 12.3, and preceded by an "authenticated request under state commercial session laws" demanding an "authenticated accounting" of the debt. The court described the filing as "[u]sing legal jargon of the type generally associated with 'sovereign citizens'" and the theory as Raspaldo's "own perplexing interpretation of intertwining laws and regulations"; "Raspaldo's claim and argument is rejected as frivolous", the Complaint is "factually and legally baseless", DISMISSED WITH PREJUDICE, and "[l]eave to amend would be futile." The accompanying Order further certifies "that any appeal from this Order is not taken in good faith" under § 1915(a)(3) — TWO PORTABLE NON-IDEOLOGY HOLDINGS, which sovereign-citizen foreclosure complaints regularly make necessary: first, the bolted-on § 1983 count fails at the threshold because "Wilmington Trust Company is a private bank, and PHH Mortgage is a private mortgage servicer and lender. They are not state actors" (citing West v. Atkins, 487 U.S. 42, 48 (1988); Groman v. Twp. of Manalapan, 47 F.3d 628, 638 (3d Cir. 1995); Bailey v. Harleysville Nat'l Bank & Tr., 188 F. App'x 66, 68 (3d Cir. 2006) (per curiam); and Burton v. Wells Fargo Bank, N.A., 738 F. Supp. 3d 272, 297 (E.D.N.Y. 2024)); second, the FDCPA count under 15 U.S.C. § 1692f(6)(A) fails because it rests on the same extinguishment premise — the security interest is unenforceable only if the obligation was in fact discharged. SCOPE — this is a § 1915 screening dismissal of a complaint that was never served or answered, not an adjudication on a defended record. And the theory rejected is discharge-at-par — the note is said to have satisfied the debt at the moment the lender took it — which is a different claim from the one that no money was ever lent and the note is void for want of consideration. Keep the two apart.).

Sumter v. Whittle, No. 3:25-cv-06982-MGL-PJG (D.S.C. Oct. 8, 2025) (Gossett, Mag. J.), adopted, No. 3:25-cv-06982-MGL (D.S.C. Oct. 29, 2025) (Lewis, J.) (Unpublished report and recommendation of a United States Magistrate Judge, adopted by the district court — persuasive authority only, not binding precedent, no reporter citation.) (redemption theory asserted over A CHILD rather than over a debt. A mother sued a family court judge, an attorney for the solicitor, and the Clerk of Family Court — the last named "in her official capacity as Custodian of Records and Trustee of Judicial Instruments" — styling herself executrix of an ecclesiastical estate trust and "Ambassador Plenipotentiary". She alleged that her son, then facing three juvenile charges, "is property of her registered trust", pleaded breach of trust, "conversion and trespass upon trust property" and "violation of due process and ecclesiastical standing", and sought a declaration of authority over "the minor trust res" together with an order that the charges against him "arise from commercial activity" and are therefore dischargeable under the Uniform Commercial Code. Held: "Although Plaintiff does not use these terms, her underlying rationale appears to stem from the “redemption” theory commonly associated with the sovereign citizen movement", and "As Plaintiff’s claim is based on the same untenable legal theory, it is legally frivolous and should be summarily dismissed" — citing Bryant, 524 F. Supp. 2d at 757–60, and Vachon v. Reverse Mort. Sol., Inc., No. EDCV 16-02419-DMG (KES), 2017 WL 6628103 (C.D. Cal. Aug. 11, 2017) (redemption theory "dismissed as patently frivolous by courts . . . across the country") — SCOPE — three limits, each of which changes what this will carry. First, frivolousness is an ALTERNATIVE holding and says so: the leading ground is dismissal under Rule 41 for failure to prosecute and failure to comply with an order directing her to obtain counsel, because she could not proceed pro se on behalf of a trust or her son, and the second ground is want of subject-matter jurisdiction; the frivolousness section opens "Alternatively". Second, the recommendation was adopted WITHOUT OBJECTION, so the district court satisfied itself only that there was no clear error on the face of the record and made no de novo determination — cite the disposition as an adoption on clear-error review, never as a considered district-court holding. Third, the court supplied the ideological label itself and said so; the filer never used the vocabulary. That is the most portable thing here: cite it for a court identifying redemption theory from the STRUCTURE of a claim — a trust asserted over a person, and a criminal charge recharacterised as a commercial obligation — rather than from any sovereign-citizen words on the page. On the commercial-code point the court held the Uniform Commercial Code to be model law only, furnishing no basis for federal jurisdiction, quoting Moss v. Stanley, No. 8:20-3194-DCC (D.S.C. Oct. 16, 2020); that sentence belongs to Moss, and a string cite crediting it here has shortened the chain.).

United States v. Turner, 985 F. Supp. 2d 1311 (M.D. Ala. 2013) (Thompson, J.) (No. 1:12cr169-MHT, ECF No. 152), aff'd, No. 13-13613 (11th Cir. 2014) (unpublished) (the criminal consequence for a promoter. The defendant was the primary speaker at seminars in 2008 and 2009 that taught paying attendees a process said to make all of their debt disappear, built on "a conspiracy theory of sorts positing that various parts of the United States government (and perhaps even the government itself) are illegitimate." Attendees prepared "bonds" addressed to the Secretary of the Treasury, claiming accounts worth $300 million or $100 billion linked to a birth certificate or Social Security number, and providing that the Secretary had thirty days to return them, after which "Failure to return the Bond as stated shall constitute Acceptance and Honoring of this Bond". A jury convicted him on every count of a ten-count indictment, including passing a fictitious obligation under 18 U.S.C. § 514 and aiding attendees who filed their own. Denying acquittal, the court held that to come within the statute "the false document must claim a power or entitlement that is grounded in the authority of the United States", and that a jury could find these bonds did so because they purport to bind the Treasury to honor them; the defendant's actions were "well within the ambit of § 514; therefore, his convictions must stand." SCOPE — the passage beginning "Failure to return" is the text of the bond, not the court. The court distinguished a document that merely asks a government agency for a benefit on a mistaken view of the law, which does not claim authority to bind the government, and expressly declined to define the statute's outer limits.).

United States v. Hutson, No. 16-cr-00186-MSK-GPG (D. Colo. Jan. 10, 2018) (Krieger, C.J.) (ECF No. 145) (Unpublished district-court opinion — persuasive authority only, not binding precedent.) (redemption offered as a religion. Charged with false claims, fictitious financial instruments and bank fraud for invoices sent to a federal agency with checks drawn on his closed account, a member of a self-declared state "republic" sought a defense under the Religious Freedom Restoration Act. The opinion records the redemption ritual in detail as he testified to it: mailing his birth certificate, Social Security card and a check on a closed account to government agencies, treating their silence as acceptance, and then drawing on a "birth certificate fund" as a "secured party creditor" with hand-altered routing and account numbers. The court accepted that his beliefs were sincere but held them not religious: they "are essentially political and secular, with only an incidental connection to matters of religion", and "At bottom, the ritual of redemption appears to be primarily (if not purely) fiscal in nature". "Beliefs devoted to accessing earthly riches held by the government are far from such transcendental concerns." The national organization's own doctrinal statement, which he adopted, said: "This is not a religion; this is God's divine order of things." In the alternative, the prosecution did not burden the ritual at all: had he "simply completed the redemption ritual and done nothing more, no charges would have been filed against him"; and prosecuting fraud was the least restrictive means of serving a compelling interest. Convicted on all counts; affirmed on other grounds, No. 18-1206 (10th Cir. Nov. 4, 2019).

SCOPE — the appeal challenged only the false-claims counts and did not reach this ruling. The court stressed that its holding does not disparage the intensity of the beliefs: "A person can possess powerful and strongly-held beliefs without those beliefs being religious.").

Bautista v. Capital One Fin. Corp., No. 3:24-cv-03010-N-BT (N.D. Tex. July 25, 2025) (Rutherford, M.J.) (ECF No. 38), adopted, ECF No. 43 (N.D. Tex. Aug. 19, 2025) (Godbey, J.) (Unpublished magistrate judge's findings and recommendation, adopted by the district judge — persuasive authority only, not binding precedent.) (bills of exchange offered to a bank as payment. The filer, styling himself the agent and attorney-in-fact of his own name, styled as a trademarked "Principal", sued the lender for refusing his "Bills of Exchange" as payment of the account and alleged he had "made numerous attempts to set off the outstanding debt on behalf of the Principal". The recommendation, at 8: "And the Bills of Exchange legal theory has been consistently rejected by the courts as frivolous." Dismissed with prejudice under Rule 12(b)(6).

SCOPE — the dismissal rests first on contract law (no contract identified, no damages pleaded); the bills-of-exchange sentence is an additional reason, so cite it for that rejection, not as a full analysis of the theory.).

UCC / commercial-paper immunity / secured-party / "accepted for value" / misuse of UCC filings

United States v. Benabe, 654 F.3d 753, 767 (7th Cir. 2011) (claimed status as a 'secured-party creditor' does not place a person beyond court jurisdiction).

Gilbert v. Monaco Coach Corp., 352 F. Supp. 2d 1323 (N.D. Ga. 2004) ("The UCC, itself, is not the law of any state, nor is it federal law"; a claim must rest on a state's codification of it — consumer warranty case, cited for the status of the UCC as model law only, not for any jurisdictional holding).United States v. Perkins, 787 F.3d 1329 (11th Cir. 2015), aff'g 2013 WL 3820716 (N.D. Ga. July 23, 2013) (UCC and admiralty-based jurisdictional arguments rejected; absence of a contract with the court does not strip it of jurisdiction).

MacArthur-Brooks Estate v. Moreno, No. 24-cv-24273-RKA, ECF No. 29 (S.D. Fla. Jan. 3, 2025) (Altman, J.) (a $2.9 billion complaint premised on 'TACIT PROCURATION' — the theory that defendants' silence on a Commercial Affidavit and Contract and Security Agreement constituted admission of liability. NOT A DISMISSAL. The mandate is "This action is REMANDED to the Eleventh Judicial Circuit in and for Miami-Dade County, Florida" — the court declined federal-question jurisdiction and returned the case to state court, so cite it for a federal court refusing jurisdiction over affidavit-based sovereign paper, never as a merits rejection. The order also strikes every plaintiff filing because "a nonlawyer trustee has no authority to represent a trust in court".).

Katrina Allen v. Blackbaud, Inc., No. W2025-01484-COA-R3-CV (Tenn. Ct. App. July 9, 2026) (Tennessee Court of Appeals — authored panel opinion; pending official reporter citation) (UCC negotiable-instrument/tender-of-payment framing under Tenn. Code Ann. §§ 47-3-104, 47-3-505, 47-3-603(b) as part of civil redemptionist/breach-of-contract theory rejected; dismissal affirmed; frivolous-appeal damages under Tenn. Code Ann. § 27-1-122).

Moore v. State, No. 11-25-00008-CR (Tex. App.—Eastland July 23, 2026) (Unpublished memorandum opinion — not designated for publication, Tex. R. App. P. 47.2(b); persuasive authority only, not binding precedent) (UCC 1-308 / reservation-of-rights notation rejected as conferring no immunity from criminal jurisdiction or liability).

Maule v. Capital One, N.A., No. 3:25-CV-417-TAV-DCP (E.D. Tenn. July 23, 2026) (Varlan, J.) (summary judgment for defendant; homemade "Bill of Exchange" tendered as UCC Article 3 payment and UCC § 3-505 non-response-as-"tacit agreement" theory both rejected as frivolous; collecting Wilson v. Abound Credit Union, No. 3:24-cv-446, 2024 WL 5089568 (W.D. Ky. Dec. 12, 2024), Campbell v. Foursight Capital, LLC, No. 3:25-cv-22, 2025 WL 2172546 (S.D. Ohio July 31, 2025), Kennebrew v. PNC Bank, No. 1:25-cv-13, 2025 WL 801169 (E.D. Tenn. Mar. 13, 2025), and Bryant v. Washington Mut. Bank, 524 F. Supp. 2d 753 (W.D. Va. 2007) rejecting the Bill of Exchange theory).

Ford v. Antonides, No. 2:22-cv-384-JES-KCD, Doc. 15 (M.D. Fla. Oct. 26, 2022) (Steele, J.) (Unpublished district-court screening order — persuasive authority only, not binding precedent, no reporter citation; dismissed under 28 U.S.C. § 1915(e)(2)(B)(i), (ii) at screening, before service and without an answer, so there is no defended record.) (the administrative-default / notice-series chain held on its own terms, and from an unusual angle. After a traffic stop the plaintiff sent the clerk’s office a "jurisdictional challenge" by notary presentment; when it was "dishonored" the office issued him "a certificate of non-response, a certificate of non-performance, a certificate of default, and a certificate of service", which he recorded and then sued upon. The court did not merely hold the chain unsupported by law — it read the paper as an ADMISSION BY ITS OWN AUTHOR: "And by complaining that he was issued certificates of non-response, non-performance, default, and service by the clerk’s office, Plaintiff acknowledges that he did not appear before a judge in state court when provided the opportunity to do so." Paired holding on the demand that precedes such a chain: "nothing in the Constitution suggests that a defendant is entitled to an immediate appearance before a judicial officer upon demand or that a state employee’s refusal to acquiesce to that demand subjects that employee to civil liability." The court further held it "illogical" to blame clerk’s-office employees for the charging decision, since "The prosecutor has the sole discretion to charge and prosecute criminal acts" (quoting State v. Greaux, 977 So. 2d 614 (Fla. 4th DCA 2008)) — SCOPE — distinguish Ford from Kriemelmeyer and Maule: those reject silence-as-acquiescence for want of any supporting law, whereas Ford ACCEPTS the certificates as evidence and turns them against the filer. Cite Ford for that evidentiary consequence, never for the no-law-supports-it proposition, which the other two carry better. The order’s right-to-travel half — the "Traveler – not for hire. Private Property." windshield placard, rejected as frivolous on a Sterling / Benabe / Reed v. Jones / Trevino string — is cumulative of Aristilde, and Ford adds nothing further on that theory. Younger abstention appears as an INDEPENDENT ALTERNATIVE ground; do not attribute the frivolousness holding to it. The opinion also block-quotes Kalinowski, 80 Mont. L. Rev. 153, 167–68 (2019), at pp. 7–8.).

Johnson v. Internal Revenue Service, No. 1:25-cv-02117 (D. Md. Sept. 11, 2026) (Abelson, J.) (Unpublished district-court memorandum opinion — persuasive authority only, not binding precedent, no reporter citation.) (the reservation formula written onto a federal tax return, and what it cost the filer. Seeking a $1,543.71 refund for tax year 2021, the taxpayer did not sign the Form 1040X jurat and instead wrote "Without Recours[e] Without Prejudice" over his signature. The jurat is "the place in the return that is provided for the signature of the taxpayer" (quoting Sloan v. Comm'r, 53 F.3d 799, 799 (7th Cir. 1995)), and 26 U.S.C. § 6065 requires that a return "contain or be verified by a written declaration that it is made under penalties of perjury", a requirement 26 C.F.R. § 301.6402-2 imposes again on the refund claim itself. Held: "by adding the phrase 'without recourse without prejudice' to his signature, Plaintiff did not sign Form 1040X under penalties of perjury as required. Therefore, the form did not qualify as a return, and Plaintiff's claims must be dismissed." The refund suit was therefore barred, because 26 U.S.C. § 7422(a) permits none until a claim has been "duly filed". Two closing routes were held shut as well: the agency "cannot waive" the § 6065 signature requirement (citing Brown v. United States, 22 F.4th 1008, 1013 (Fed. Cir. 2022), and Angelus Milling Co. v. Comm'r, 325 U.S. 293, 296–97 (1945)), and the letter declining to process the form for want of a Schedule A did not "examine the merits" of the claim, so it waived nothing under the regulation either. On the qualification itself: "[T]he guessing games engendered by qualifications like [Plaintiff's] are an unreasonable impediment to the administration of the nation's tax laws" (quoting Sloan v. Comm'r, 102 T.C. 137, 146 (1994), the Tax Court decision the Seventh Circuit affirmed in the Sloan opinion cited above) — SCOPE — this opinion never uses the words "sovereign citizen" or "frivolous", and it reaches no holding about any ideology; it also expressly declined to decide whether the "duly filed" requirement is jurisdictional, analysing the dismissal under Rule 12(b)(6) rather than Rule 12(b)(1) — cite it for the legal effect of a rights-reservation formula placed over a mandatory penalties-of-perjury declaration, never as a court rejecting sovereign-citizen theory. The memorandum closes "An appropriate order follows"; the order effecting the dismissal is a separate document.).

Williams v. City of Glendale, No. 26NNCV00519 (Cal. Super. Ct. L.A. Cnty. Aug. 14, 2026) (Tavelman, J.) (Unpublished trial-court ruling on demurrer — no precedential value; persuasive authority only. Judgment entered Sept. 4, 2026, and subject to appeal.) (the utility-bill version of the theory. The plaintiff stamped his municipal electric bills "WITHOUT RECOURSE" and "Pay to the Order of: Bearer", signed them in his own name as "agent", and sent them back as payment, contending that each stamped bill was a draft the city had to accept or dishonor and that Cal. Evid. Code §§ 633 and 634 presumed it paid. The court rejected each step: "The Evidence Code is not meant to be used as a sword and shield for payment obligations or to shift the burden of who pays bills"; returning the stamped bills "does not negate his obligation to make payments on the bills or shift the draft holder to Defendant"; Cal. Com. Code § 1305 "does not stand for the proposition that damages are not required for a Commercial Code claim"; and "Plaintiff has not alleged under the law how his stamped bills constitute a negotiable instrument." Demurrer sustained without leave to amend on three independent grounds — res judicata from an earlier small-claims judgment on the same theory over the prior year's bills, no statutory basis for liability, and uncertainty — so the negotiable-instrument holding is an alternative ground. The ruling does not characterize the plaintiff or use any sovereign-citizen label; cite it for what a stamped or endorsed bill does, never as a court rejecting sovereign-citizen theory.).

Knapp v. Compass Minnesota, LLC, No. 0:24-cv-00100, 2024 WL 2832502 (D. Minn. June 4, 2024) (Nelson, J.), aff'd in part and appeal dismissed in part, No. 24-2722 (8th Cir. Jan. 24, 2025) (per curiam) (Unpublished district-court opinion and unpublished per curiam — persuasive authority only, not binding precedent.) (the theory carried out through a power of attorney. Home buyers appointed a non-lawyer as their "attorney-in-fact"; he declared their real-estate purchase and listing contracts to be "collateral securities" and ordered their broker to exchange them for Federal Reserve Notes under 12 U.S.C. § 412, and they sued the broker for refusing. Dismissed with prejudice: each contract carried an express condition to payment, so none was a negotiable instrument, and "As the Contracts cannot be plausibly characterized as negotiable instruments or securities of any kind under state or federal law, and as Defendants are not banks, the Contracts cannot be redeemed as" bills of exchange for Federal Reserve Notes; the court identified the argument as a version of the redemption scheme called the "vapor money" theory. On the power of attorney: under Minnesota law "a power of attorney does not authorize a non-attorney to act as an attorney on behalf of the principal", and "ordering Defendants to communicate with an individual engaged in the unlicensed practice of law would place Defendants in an absurd position." The court took judicial notice that the representative's organization is "an entity that concedes that it engages in the unlicensed practice of law as a matter of course." Rule 11 sanctions followed (Doc. 71, Aug. 9, 2024): the claims were "definitionally frivolous" and the complaint "baseless in its entirety", and attorney's fees and costs of $36,520.63 and $27,816.83 were awarded to the two defendants; the court added that "Participating in the unlicensed practice of law is also sanctionable in and of itself." The Eighth Circuit affirmed the sanctions and dismissed the rest of the appeal because "the notice of appeal was filed more than 30 days after the judgment granting the defendants' motion to dismiss", so the dismissal itself was never reviewed on the merits. Cite for the collateral-securities and power-of-attorney holdings and the sanctions; the court's remark that the organization's website endorses beliefs "consistent with the Sovereign Citizen movement" describes a non-party's website, not a finding about these plaintiffs.).

Boeve v. Southstate Bank, N.A., No. 8:24-cv-00647 (M.D. Fla. June 20, 2024) (Barber, J.) (Unpublished district-court order — persuasive authority only.) (a mortgagor tried to pay his loan with "another entire promissory note in order to perform on the mortgage" and sued when the servicer refused, pleading breach of contract, the Federal Reserve Act, and peonage, slavery and forced-labor statutes. Every count was dismissed without leave to amend: the contract claim "is based on the patently frivolous vapor money theory, this claim is dismissed without leave to amend"; the fiduciary claim rested on "redemptionist legal theories that have been uniformly rejected as a frivolous waste of court resources" (quoting Thomas v. BMO Harris Bank, No. 23-00224-TFM-B, 2024 WL 477542, at *8 (S.D. Ala. Jan. 19, 2024)); and "requiring Plaintiff to pay his mortgage using legal tender does not implicate slavery at all.").

Marfoe v. Discover Bank, No. 1:24-cv-01894 (N.D. Ill. Jan. 6, 2025) (Coleman, J.) (Unpublished district-court memorandum opinion — persuasive authority only.) (a cardholder mailed her own billing statements back as "bills of exchange", pleading that "[p]roper performance would have been to indorse the original collateral securities under special negotiation, prior to them being exchanged for Federal Reserve Notes." The court observed that "although Plaintiff disclaims any association with the group, her complaint bears the hallmarks of the legal theories espoused by the" sovereign-citizen movement, held that "to equate the requirement that one payoff her credit card debt with chattel slavery is, in a word, reprehensible", and dismissed the federal counts with prejudice and the state-law counts without prejudice, declining supplemental jurisdiction. Leave to amend was denied because "granting Plaintiff leave to amend would only serve to incentivize such frivolous filings"; the court noted an earlier suit of hers on the same theory had been dismissed as frivolous.).

Bonilla v. Capital One, N.A., No. 3:24-cv-00377 (D. Or. July 26, 2024) (Nelson, J.) (Unpublished district-court opinion — persuasive authority only.) (the cardholder sent the bank "his own billing statements with instructions that they be used as a" negotiable instrument to pay the balance, and proposed to amend to allege that he "is able to legally create currency because it is a Federal Reserve member bank." The court held that "Plaintiff's legal claims are frivolous", denied leave to amend as futile, dismissed with prejudice, and certified that any appeal would not be taken in good faith.).

Moore v. Discover Bank, No. 1:24-cv-03194 (S.D.N.Y. May 28, 2024) (Swain, C.J.) (Unpublished screening order under 28 U.S.C. § 1915(e)(2)(B) — persuasive authority only.) (the plaintiff alleged that "all promissory [notes] produced by Shemar Raymond Moore are under the purview of 18 U.S.C. § 8" and directed the bank to "apply the positive value of the negotiable instruments on the account to set off the account and bring it to zero." Dismissed as frivolous without leave to amend: "The Court agrees with the many decisions that have dismissed similar claims as frivolous and without merit." Any appeal was certified as not taken in good faith.).

Paul v. State of New York, No. 2:13-cv-05047 (SJF)(AKT) (E.D.N.Y. Nov. 5, 2013) (Feuerstein, J.) (ECF No. 9) (Unpublished district-court order — persuasive authority only, not binding precedent, no reporter citation; an appeal was taken, and the Second Circuit's mandate issued July 1, 2014.) (the plaintiff described himself as "a Non-Adverse, Non-Belligerent, Non-Combatant, and Secured Party/Bailor" and attached UCC financing statements to a complaint denying the state's power to prosecute and supervise him. The court treated the filings themselves as identifying the theory: "It is clear from plaintiffs amended complaint and the Uniform Commercial Code ('UCC') financing statements attached thereto" "that he is an adherent of the 'sovereign citizens' movement". The amended complaint was "sua sponte dismissed in its entirety with prejudice as frivolous", leave to replead being futile because the problem was substantive. SCOPE — the court did not analyse the financing statements as instruments; its rejection of the jurisdictional theory rests on authorities it quotes, including Santiago and Ulloa, so cite this order for how such filings are read, not as an independent holding on UCC law.).

Strawman / ALL-CAPS name / corporate-person / flesh-and-blood vs. legal entity

United States v. Benabe, 654 F.3d 753, 767 (7th Cir. 2011) (regardless of claimed status—'sovereign citizen,' 'secured-party creditor,' or 'flesh-and-blood human being'—the person is not beyond court jurisdiction; theories rejected summarily).

Monroe v. Beard, 536 F.3d 198, 203 n.4 (3d Cir. 2008) (per curiam) (describing the Redemptionist dual-entity claim as a "split personality: a real person and a fictional person called the 'strawman'"; n.4 is definitional background from Cracking the Code, not a jurisdiction holding — see Benabe for the jurisdictional rejection).

United States v. Jones, 65 F.4th 926, 930 (7th Cir. 2023) ("sovereign-citizen theories are not just 'bizarre,' . . . they also reflect misunderstandings about criminal jurisdiction" (citation omitted)).

United States v. Heijnen, 375 F. Supp. 2d 1229, 1231 (D.N.M. 2005) (defendant argued his name in capital letters in the indictment caption was "not his name, but the name of some fictitious entity"; argument rejected and motion denied).

Adams v. City of Marshall, No. 4:05-cv-62 (W.D. Mich. Oct. 24, 2005) (Miles, J.) (all-caps captioning "complies with FED. R. CIV. P. 10(a)" and "is a typographical convention without legal significance" (quoting Heijnen); no legal authority supports the contrary position; collecting United States v. Rogers, 16 F. App'x 38 (2d Cir. 2001) and United States v. Beaner, 2005 WL 1503217 (D.S.D. June 25, 2005) (capital-letter argument frivolous)).Sower v. Rocket Financial Inc., No. 3:26-cv-202-YY (D. Or. Apr. 29, 2026) (letter purporting to instruct U.S. Treasury to discharge personal debt via strawman account held legally baseless; Treasury-discharge-letter theory rejected).

Wright v. Arrendale, No. CV-25-04051-PHX-KML, 2025 WL 3041897 (D. Ariz. Oct. 31, 2025) (Liburdi, J.) (secured-party-creditor and Treasury-payment theory rejected: plaintiff made a "special appearance as the secured part creditor and rightful, factual and true beneficiary of the Melissa Brooke Wright Estate" [sic — the order's own text], claimed she had cleared mortgage arrears with an "IRS Payment" directing the United States Treasury to pay on her behalf, and objected to being required to "pay for said [m]ortgage with Federal Reserve [n]otes" which "are not backed by gold or silver coin". Held these are "some of the hallmarks of filings by 'sovereign-citizens'", that such arguments have been "consistently and thoroughly rejected by every branch of the government for decades", and that the complaint is therefore "patently frivolous such that the court lacks jurisdiction"; DISMISSED WITHOUT PREJUDICE. Quotes United States v. Murphy, 824 F.3d 1197, 1204 n.1 (9th Cir. 2016) for the belief that adherents "can access virtually unlimited sums from secret accounts created for them when the United States went off the gold standard in 1933". SCOPE — the court says "secret accounts" and "estate"; it does NOT use the word 'strawman').

United States v. Miller, No. 1:24-cr-00164-TSC (D.D.C. May 13, 2024) (Chutkan, J.) (ECF No. 23) (January 6 prosecution; self-represented defendant with standby counsel sought judicial notice of his "resignation as 'registered agent, representative and principal,'" that "the Plaintiff is dead/deceased and that the 'Prosecutor' is acting under color of law abusing an alleged Power of Attorney which died with the Plaintiff", and that "the Principal, the Plaintiff, and the prosecutor, the agent for the Principal, lack standing in this matter". DENIED on Federal Rule of Evidence 201: "As the court confirmed at the May 2, 2024, arraignment, Defendant is not dead or deceased", and "neither fact Defendant asks the court to judicially notice is 'generally known' and Defendant's sources are not those 'whose accuracy cannot reasonably be questioned.' Judicial notice is not warranted". All three pro se motions denied, and "no further filings will be accepted prior to the next status conference". SCOPE — the court does NOT use the words 'strawman', 'dual entity' or 'no basis in law', and reaches no holding framed in those terms; it disposes of the motion on Rule 201 and on 8 U.S.C. § 1481(a) — the renunciation holding is cited separately.) Trevino v. Florida, 687 F. App'x 861, 862 (11th Cir. 2017) (Unpublished opinion — not precedential under 11th Cir. R. 36-2; persuasive authority only, not binding precedent) (dismissed as frivolous a lawsuit brought by a self-described 'living, breathing, flesh and blood human being').

Henry v. Fernandez-Rundle, 773 F. App'x 596, 597 (11th Cir. 2019) (Unpublished opinion — not precedential under 11th Cir. R. 36-2; persuasive authority only, not binding precedent) (collecting cases and holding that claims brought as a 'sovereign citizen,' 'secured-party creditor,' or 'flesh-and-blood human being' are routinely rejected as frivolous).

Townsend v. Georgia, No. 4:18-cv-00303, 2019 WL 1009421 (S.D. Ga. Feb. 11, 2019) (Ray, M.J.) (docketed as Nazari v. State of Georgia; the plaintiff is Bruce Townsend, aka Ras Lazarus Nazari) (REPORT AND RECOMMENDATION — a magistrate's recommendation, not an order; it recommends dismissal under 28 U.S.C. § 1915(e)(2) and grants IFP. ADOPTED IN FULL by the district court after de novo review: Order, Doc. 11 (S.D. Ga. Mar. 1, 2019) (Baker, J.), overruling the objections and adopting the Report and Recommendation as the opinion of the Court; judgment entered March 7, 2019. Pro se plaintiff, a self-described Rastafarian "Public Minister" filing as "Ras Lazarus Nazari" on behalf of the all-caps DEBTOR form of his own name, invoked UCC §§ 3-403, 1-207, 1-308, 3-410 and 1-103 and styled himself "the living Human being, a living soul, sui juris, Foreign Sovereign and holder in due course of the commercial vessel, commercial trade name, en legis known as" that name. The court found the filings "legalistic gobbledygook" and held the "language has all the hallmarks of the 'sovereign citizen' theory that has been consistently rejected by the federal courts as an utterly frivolous attempt to avoid the statutes, rules, and regulations that apply to all litigants", characterising the third-person self-reference as "a living Human being" and "living soul" as "typical of such frivolous sovereign-citizen claptrap". SCOPE — "commercial trade name" appears ONLY inside the court's block quotation of the plaintiff's own filing and receives no separate characterisation; do not attribute a holding on it. Two features worth noting: the plaintiff expressly DISCLAIMED the label, insisting the record showed he never "made any claim to be a sovereign citizen" — the same disclaim-the-label move as Henry v. Fernandez-Rundle — and the court quotes United States v. Perkins for the observation that sovereign citizens often file "lots of rambling, verbose" pleadings that "rely heavily on the Uniform Commercial Code").

Banks v. Pompeo, No. 2:19-cv-00755 (M.D. Fla. Fort Myers Div. Dec. 11, 2019) (Mizell, M.J.) (REPORT AND RECOMMENDATION — a magistrate's recommendation, not an order. The same litigant filed 2:19-cv-00754 and 2:19-cv-00756 the SAME DAY; 756 is the “Banks v. Florida, No. 19-756” collected in Wright v. Arrendale. Screening under 28 U.S.C. § 1915(e)(2)(B) of a filing captioned as a "Treaty" and "Notice of Estoppel and Stipulation of Constitutional Challenge" to all District of Columbia and state statutes. The dual-entity theory is stated unusually plainly: plaintiff asserted he is the "1st lien holder of the 14th amendment person Eddie Alexander Banks, corp. sole dba EDDIE ALEXANDER BANKS" who "did not consent for me or my private property to being a 14th amendment citizen of the U.S. or STATE OF FLORIDA", "especially since this was done by my mother without full disclosure when I was a baby" — the birth-registration-without-consent premise underlying the strawman split. Also invokes an "Act from 1871" (the District of Columbia Organic Act theory) — held the filing "unintelligible and incomprehensible" and failing Fed. R. Civ. P. 8, and "wholly insubstantial, unintelligible, and frivolous"; recommended IFP be DENIED and the action DISMISSED "without affording Plaintiff an opportunity to amend". NOTABLE — the court reached the ideology over the litigant's silence on it: "while Plaintiff does not assert that he is a 'sovereign citizen,' his arguments appear similar to the sovereign citizen arguments that courts have routinely dismissed as frivolous" (quoting Mitchell v. Vesely) — the R&R also quotes, from the plaintiff's filing, "CFN # 110651873" — that is a real Broward County recorded instrument, OR BK 48621 Page 548, recorded 03/29/2012, a six-page "Declaration of PEACE TREATY" / land-patent and living-will package asserting a $58,000,000.00 "SPECIAL DEPOSIT/BAILMENT BOND").

Lux Veritas E.E. Trust v. Wayne Service, Inc., No. 2:26-cv-11960 (E.D. Mich. July 8, 2026) (Berg, J.) (unpublished district-court order) (plaintiff described himself as "a living man, a natural person created by God," denied he was the "PERSON on the DOCKET 'SEDLOCK/NICHOLAS/DAVID/PAUL,'" and signed "All Rights Reserved without recourse UCC 1-308"; court held he "does not explicitly identify himself as a sovereign citizen" but the allegations nonetheless "bear all the hallmarks of similar claims that use the sovereign citizen term" and dismissed the complaint as based on "frivolous theories that warrant dismissal under Apple v. Glenn and Younger").

United States v. Coleman, 871 F.3d 470, 476 (6th Cir. 2017) ("Defendant's legal arguments directly correspond to meritless rhetoric frequently espoused by tax protesters, sovereign citizens, and self-proclaimed Moorish-Americans"; collecting cases in which other courts rejected sovereign-citizen jurisdictional theories as frivolous, including Benabe and Vallone. The appeal itself concerned competency to stand trial, and the conviction was affirmed on that ground).

United States v. Dowtin, No. 3:25-CR-32 (S.D. Ohio Feb. 6, 2026) (an evidentiary-exclusion ruling rather than a merits dismissal — motion in limine sustained, keeping sovereign citizen ideology from the jury, including claims that defendant was a private trust, that the flesh-and-blood man was not properly charged, that all-caps name had unique legal meaning, and that the court lacked jurisdiction; excluded under Fed. R. Evid. 401, 402, and 403 as contrary to prevailing law. Cite for what may be kept from a jury, not as an example of a claim dismissed on the merits).

United States v. Dowtin & McCall, No. 3:25-cr-00080, Doc. #111 (S.D. Ohio Feb. 17, 2026) (Rice, J.) (companion order in the co-defendant case eleven days after the Feb. 6, 2026 order in United States v. Dowtin, reaching the same result as to both defendants and adding jury-nullification and mistake-of-law grounds; same evidentiary-exclusion posture — cite for what may be kept from a jury, not as a merits dismissal).

Brookins v. Schroeder, No. 2:24-cv-07856-GRB-ST (E.D.N.Y. Jan. 14, 2026) (Brown, D.J.) (Order Adopting the Report and Recommendation of Tiscione, M.J.; case arose from a traffic stop and three tickets, the plaintiff suing the DMV Commissioner, a state district court, three judges, the District Attorney and a police officer, and captioning himself "an Unicorporated [sic] Natural Man on the Land and Living Soul, Standing In Propria Persona, Sui Juris", a/k/a Jawan Bey. The court denied the plaintiff's motion to STRIKE the sovereign-citizen characterisation from the magistrate's report, noting the complaint had explicitly claimed that status at ¶ 83: he "does not have to comply with any Public Official's presumed jurisdictional authority without his informed consent in his lawful and legal status as an unincorporated private American Citizen who is sovereign in his own right as one of the people". Objections to the R&R "fail to raise any colorable objection"; motions to dismiss GRANTED for lack of jurisdiction under Rule 12(b), complaint dismissed with prejudice in its entirety and without leave to replead, sanctions and compel motions denied, in forma pauperis denied for any appeal. SOURCE CAUTION — the Jan. 14 order itself was not available. Every element above is taken from two documents that quote or recite it: the clerk's Judgment (Doc. 109, 01/23/26) and the State Defendants' opposition brief (Doc. 112, 02/26/26), the latter a party filing rather than authority).

United States v. Williams, 29 F.4th 1306 (11th Cir. 2022) (affirmed rejection of the sovereign citizen argument that "the United States is not a person" and therefore cannot prosecute; district court described such arguments as "bogus, unsubstantiated, illogical" and a "sure fire guarantee of a conviction").

Shephard v. Wells Fargo Bank, N.A., No. 2:25-cv-01885-APG-NJK (D. Nev. June 23, 2026) — all-caps name cited as sovereign citizen signifier; "Commercial Security Agreement" between "real woman" and all-caps strawman version dismissed as frivolous. Katrina Allen v. Blackbaud, Inc., No. W2025-01484-COA-R3-CV (Tenn. Ct. App. July 9, 2026) (Tennessee Court of Appeals — authored panel opinion; pending official reporter citation) (durable power of attorney separating the "real person" from the ALL-CAPS strawman name as part of civil redemptionist/breach-of-contract theory; dismissal affirmed; frivolous-appeal damages under Tenn. Code Ann. § 27-1-122 — claims "utterly devoid of merit").

Moore v. State, No. 11-25-00008-CR (Tex. App.—Eastland July 23, 2026) (Williams, J.) (appellant Denver Moore) (Unpublished memorandum opinion — "Do not publish" under Tex. R. App. P. 47.2(b); persuasive authority only, not binding precedent. Trial Court Cause No. 22-03468-CRF-361, 361st District Court, Brazos County, transferred to Eastland by docket-equalization order) (the FACTS state the identity-split unusually cleanly: appellant told the court "I'm not him. The person that you call Denver Moore, that's not me", addressed it as "Administrator trustee under constructive trust 22-03468" and asked it to "dissolve this constructive trust", and refused to be "categorized as a legal fictional entity" on the theory that a person means "a corporation, association, partnership". SCOPE — the appellate court does NOT reject these theories on the merits. It records them and uses them to analyse competency and self-representation, affirming on both issues. the opinion never uses "frivolous", "without merit" or "no basis"; the only "irrelevant" is the trial court's remark; and "strawman" never appears — that is a classification label, not the court's word. Cite it for the fact pattern, and for the competency holding, not as a merits rejection).

Santiago v. Century 21/PHH Mortgage, No. 1:12-cv-02792-KOB, 2013 WL 1281776, at *5 (N.D. Ala. Mar. 27, 2013) (Bowdre, J.) (Unpublished district-court opinion — persuasive authority only, not binding precedent. A CIVIL mortgage action the borrowers themselves filed against their loan servicer, reaching a merits disposition: the servicer's motion for judgment on the pleadings GRANTED. After that motion was under submission the plaintiff filed an "Affidavit of Status As Secured Party And Creditor" asserting two identities for one man — "HECTOR R. SANTIAGO ©, A LEGAL ENTITY FOR USE IN COMMERCE" and a hyphenated-forename form styled "A Living, Natural Male, and Secured Party" — and sought to invalidate any contract listing his name in capital letters. Held: "The attempt to divide oneself into two separate entities, with only one being liable for incurring debts, is a legal fiction and has been struck down consistently in courts around the country." The court separately held that by filing the complaint and paying the filing fee the plaintiffs had submitted themselves to the jurisdiction of the court and were "not free to create their own rules", adding that it would "gladly accept a voluntary motion to dismiss their claims" if they wished to withdraw. Two sentences that later courts quote frequently ORIGINATE in this opinion and should be attributed to it rather than to the courts quoting it: "The conspiracy and legal revisionist theories of 'sovereign citizens' are not established law in this court or anywhere in this country's valid legal system", and, at footnote 3, "Such tactics do not create valid legal documents." — the tactics being the "use of 'affidavits' and other pseudo-legal documents that purport to require responses within a specified time or face 'legal consequences' of the author's own making". SCOPE — those footnote 3 sentences describe letters the borrowers mailed to a private mortgage servicer, not notices served on public officials, and no sanction was sought or imposed; cite it for the character of such paper, never as authority on what a self-made demand notice obliges its recipient to do).

Serpik v. Webb, Nos. 25-6110, 25-6156 & 25-6026 (10th Cir. Oct. 1, 2026) (Rossman, J.) (Unpublished order and judgment — not binding precedent; persuasive authority only under Fed. R. App. P. 32.1 and 10th Cir. R. 32.1.) (the filer argued that the charging papers named "ROMAN SERPIK", an entity, rather than "Roman Vladimirovich Serpik", the natural living man, so that his arrest, prosecution and conviction were void. The panel affirmed the dismissal of his civil-rights suit as frivolous: "Appellant's legal theory that the misidentification and prosecution of the wrong legal person deprived the court of jurisdiction lacks merit." It added that the circuit has "rejected misidentification arguments as wholly frivolous in tax disputes", and that a state supreme court order he relied on held only that he could not represent a legal entity because he is not an attorney. SCOPE — the "claimed status of descent" sentence the order quotes is United States v. Benabe's, and the capital-letters holding it cites is Ford v. Pryor, 552 F.3d 1174, 1179 (10th Cir. 2008); attribute those words to those courts.).

General jurisdiction challenges / void judgment / sovereign citizen court-as-corporation attacks / State National status claims

United States v. Schneider, 910 F.2d 1569, 1570 (7th Cir. 1990) (Posner, J.) (the source of the line every later court quotes. Conviction for making a threat by mail against a state judge, 18 U.S.C. § 876, AFFIRMED. The sentence arises inside a counsel-withdrawal analysis: "Schneider wanted to present as his sole defense the contention that he is a free, sovereign citizen and as such not subject to the jurisdiction of the federal courts", and "Since that defense has no conceivable validity in American law, the judge would not have permitted it to be presented to the jury". SCOPE — that is reasoning about why counsel could not withdraw, not a standalone merits holding on the ideology; it is nonetheless the canonical statement and is quoted as such by Benabe, Jonassen, Wright, Evitt and Requena.).

Lonsdale v. United States, 919 F.2d 1440, 1448 (10th Cir. 1990) (published Tenth Circuit decision; dismissal AFFIRMED and sanctions imposed of double costs plus $500. Enumerates ten arguments as "completely lacking in legal merit and patently frivolous", the first being that individuals — described as "free born, white, preamble, sovereign, natural, individual common law ‘de jure’ citizens of a state" — are not "persons" subject to taxation, alongside the claims that the authority of the United States is confined to the District of Columbia, that wages are not income, that the income tax is voluntary, and that no statutory authority exists for imposing an income tax on individuals. Sanctions were separately DENIED on the delegation-of-authority and Paperwork Reduction Act claims, the court finding the law in the circuit not then settled enough to treat those as frivolous as against pro se litigants.).

Charlotte v. Hansen, No. 11-1113 (10th Cir. Aug. 15, 2011) (Lucero, Ebel, Gorsuch, JJ.) (Order and Judgment — not binding precedent except under law of the case, res judicata and collateral estoppel; citable for persuasive value under Fed. R. App. P. 32.1 and 10th Cir. R. 32.1) (appellant was convicted of traffic violations in El Paso County and sued the state trial judge who presided over her trial; dismissal AFFIRMED on absolute judicial immunity, presiding over a criminal trial being an inherently judicial function. She asserted "sovereign citizen" status for the first time in her reply brief; the court held those issues were "not properly before us" and declined to address them, noting for her benefit that an individual’s belief that such status puts her beyond the jurisdiction of the courts "has no conceivable validity in American law," quoting Schneider, 910 F.2d at 1570. The sovereign-citizen observation is dicta on a waived argument; the disposition rests on judicial immunity. The appellant is captioned only as "CHARLOTTE" because she rejects the use of her surname, styling herself "Charlotte of the Kempf family" and "Charlotte d.b.a. CHARLOTTE KEMPF".).

United States v. Ulloa, 511 F. App’x 105, 106 n.1 (2d Cir. 2013) (summary order — non-precedential under 2d Cir. Local R. 32.1.1; persuasive authority only) ("The sovereign citizens are a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior." A definitional description of the ideology; the footnote is not a merits holding that the theory is legally invalid.).

United States v. Jagim, 978 F.2d 1032, 1036 (8th Cir. 1992) (The quoted words address the pro se arguments of co-appellant Depew, not Jagim, in Part I of a multi-defendant tax appeal; the arguments are Depew's, not Jagim's. Depew claimed he could not be punished under the tax laws because he was "a citizen of the sovereign state (the 'Republic') of Idaho" now claiming asylum in the "Republic of Colorado", that the IRS is controlled by a foreign entity, and that there was "no nexus, i.e., voluntary contract" between him and the government. Held: "These issues are completely without merit, patently frivolous, and will be rejected without expending any more of this Court's resources on their discussion". SCOPE — a summary refusal to engage, not reasoned analysis.).

"Courts have been confronted repeatedly by [sovereign citizens'] attempts to delay judicial proceedings and have summarily rejected their legal theories as frivolous." — United States v. Sterling, 738 F.3d 228, 233 n.1 (11th Cir. 2013).

Walker v. Florida, 688 F. App'x 864, 865 (11th Cir. 2017) (Unpublished opinion — not precedential under 11th Cir. R. 36-2; persuasive authority only, not binding precedent) (courts have repeatedly rejected sovereign citizen jurisdictional arguments as frivolous).

United States v. Palmer, 699 F. App’x 836 (10th Cir. 2017) (unpublished order denying a certificate of appealability — persuasive authority only, not binding precedent) (on a 28 U.S.C. § 2255 motion, held that "reasonable jurists could also not disagree that the claim is plainly frivolous" as to the argument that the defendant is a sovereign state citizen to whom the laws of the United States do not apply, citing 18 U.S.C. § 3231 and Benabe; certificate of appealability DENIED and the matter DISMISSED. This is a certificate-of-appealability ruling, not a merits adjudication of the theory.).

Denton v. Hernandez, 504 U.S. 25, 32-33 (1992) (Supreme Court; supplies the frivolousness standard applied on in forma pauperis screening — a complaint may be dismissed as frivolous where its factual allegations are clearly baseless, a category encompassing the fanciful, the fantastic and the delusional. Not a sovereign-citizen case and states no view on that ideology; offered for the standard alone.).

Bingham v. Thomas, 654 F.3d 1171, 1175 (11th Cir. 2011) (per curiam) (supplies the frivolousness STANDARD only, not any sovereign-citizen holding — a claim is frivolous "if it lacks an arguable basis either in law or in fact" under 28 U.S.C. § 1915A(b)(1), quoting Miller v. Donald, 541 F.3d 1091, 1100 (11th Cir. 2008) — this is a prisoner PLRA exhaustion and § 1983 appeal containing no sovereign-citizen content; disposition was affirmed in part, vacated and remanded in part. Cited for the standard the other authorities here are measured against).

United States v. Miller, No. 1:24-cr-00164-TSC (D.D.C. May 13, 2024) (Chutkan, J.) (ECF No. 23) (the renunciation half of the same order whose judicial-notice half is cited separately — one document, not two cases. The defendant claimed "he repudiated his U.S. citizenship in a document that contains only his signature and does not appear to be official". Held: "To repudiate his citizenship, Defendant would have needed to perform one of the specific acts in 8 U.S.C. § 1481(a)", and "Defendant's attachment does not appear to comply with these requirements" — note the hedge, the court wrote "does not appear to comply", not that it does not. The independent second ground applies more broadly: "Even if it did, however, noncitizens may still be prosecuted for acts committed in the United States", so renunciation would not defeat the prosecution even if it had worked. Two procedural rulings: the hearsay and authentication attack failed because "Neither the Criminal Complaint nor the Information, however, need to comply with the Federal Rules of Evidence" outside trial, per Fed. R. Evid. 1101; and the Rule 12(f) motion failed because "the Federal Rules of Civil Procedure apply to civil cases—not criminal cases".).

Smith v. State, No. 41311-0-III (Wash. Ct. App. Div. III June 16, 2026) (Unpublished opinion — Wash. Gen. R. 14.1; persuasive authority only, not binding precedent) (rejecting claim that 'person' under RCW 1.16.080(1), RCW 59.18.030(21), and RCW 46.04.405 means only legal/commercial entities excluding the filer from suit without consent; separately holding that a petition to void past judgments and enjoin future State litigation is a nonjusticiable advisory opinion under the UDJA's four-part justiciability test; petitioner's express disclaimer of 'sovereign citizen' framing did not change the analysis or outcome).

State v. Matzke, 236 Kan. 833, 835, 696 P.2d 396 (1985) (Kansas Supreme Court; the defendant claimed he had become an "Absolute Natural Person" by filing affidavits purporting to revoke all power "formerly granted" to government agencies, which he collectively called the "cestui que trust", and that Kansas was not a legal entity capable of being a plaintiff. Held: "we find them completely lacking in logic and substance" and "The court clearly had personal and subject matter jurisdiction" — in personam because he was a properly served Kansas resident, venue because the act occurred in the county, and subject matter because "Kansas district courts are courts of general jurisdiction" under K.S.A. 20-301 and 22-2601. SCOPE — the opinion never uses the phrase "sovereign citizen" and predates the modern movement; it is the argument's structure, not its label, that recurs. Relied on by State v. Freeman as controlling Kansas precedent).

State v. Freeman, No. 128,487 (Kan. Ct. App. July 10, 2026) (Unpublished memorandum opinion — not designated for publication, Kan. Sup. Ct. R. 7.04(g); persuasive authority only, not binding precedent) (self-declared "enfranchised, private man on land in Kansas Territory" status and coordinated Judicial & Administrative Notice / Notice of Right to Travel / Affidavit of Truth packet rejected as not equivalent to a proper K.S.A. 22-3208(1) motion to dismiss; K.S.A. 20-301 general jurisdiction affirmed; relies on Matzke).

Secondary sources (legal scholarship, cited by courts for the movement's definition and history — commentary, not authority, and not a basis for any legal proposition): Caesar Kalinowski IV, A Legal Response to the Sovereign Citizen Movement, 80 Mont. L. Rev. 153, 154-55 (2019) (relied on by courts for the movement's core tenet that the federal government lacks jurisdiction over non-consenting individuals; cited by United States v. Bentley, No. 24-5433 (6th Cir. 2025), State v. Evitt (N.D.), Skurdal v. Walker (Mont.), and Hout v. Alaska (Alaska)).

Francis X. Sullivan, The "Usurping Octopus of Jurisdictional/Authority": The Legal Theories of the Sovereign Citizen Movement, 1999 Wis. L. Rev. 785, 796 (1999) (historical development of the movement's jurisdictional theories; relied on by Katrina Allen v. Blackbaud (Tenn. Ct. App. 2026)).

Joshua P. Weir, Sovereign Citizens: A Reasoned Response to the Madness, 19 Lewis & Clark L. Rev. 830, 834 (2015) (movement structure and the practical problems it poses for courts; relied on by Katrina Allen v. Blackbaud (Tenn. Ct. App. 2026)).

Sinclair v. Terra, No. 2:25-cv-01533, 2025 WL 2151041 (E.D. Pa. July 17, 2025) (magistrate judge's report and recommendation), report and recommendation adopted, 2025 WL 2146837 (E.D. Pa. July 29, 2025) (§ 2254 petition resting on the petitioner's claimed sovereign status summarily dismissed without prejudice; no probable cause to issue a certificate of appealability).

Commonwealth v. McGarry, 172 A.3d 60, 65-66 (Pa. Super. Ct. 2017) (published opinion) (PCRA appellant argued that he is a "sovereign citizen" and therefore "not subject to the laws of the Commonwealth of Pennsylvania"; held that all courts of common pleas have statewide subject matter jurisdiction over Crimes Code prosecutions under 42 Pa.C.S. § 931, and that "[c]ourts in this Commonwealth and various Federal Courts of Appeals have rejected sovereign citizen claims . . . as frivolous," citing United States v. Himmelreich, 481 F. App'x 39, 40 n.2 (3d Cir. 2012) (per curiam), which cites United States v. Benabe with approval).

Earl v. Harris, No. 23-1063, 2023 WL 3580700 (3d Cir. May 22, 2023) (Unpublished non-precedential opinion — not binding precedent under 3d Cir. I.O.P. 5.7; persuasive authority only) (rejecting the contention that judges forfeit judicial immunity where the litigant "did not consent to their jurisdiction": the judges were exercising jurisdiction conferred by statute, personal jurisdiction is established by a "defendant's physical presence before the court," and "whether Earl consented to the criminal proceedings is of no consequence"; separately holding that the Eleventh Amendment bars private suits against non-consenting states "irrespective of the plaintiff's citizenship," defeating the claim that the litigant is not a citizen of the forum state).

Kehmeier v. United States, No. CV-25-04536-PHX-DJH, Doc. 20 (D. Ariz. Aug. 26, 2026) (Humetewa, J.) (sixteen years of the same claim, ending in dismissal WITH PREJUDICE. "Kehmeier is no stranger to a federal court, nor is he a stranger to the exact claim he brings in this lawsuit"; he "has filed a litany of lawsuits in this District Court, all related to protesting the authority of the federal government to tax him"; and "Though tenacious, Kehmeier is not very original because he has again filed the same claim against the same Defendant". Leave to amend denied as made in bad faith, prejudicial and futile, because "there are no cognizable legal theories that can be pled to show that the Government cannot collect federal income tax", and, decisively, "Kehmeier's Complaint echoes sovereign citizen rhetoric, something that the courts resoundingly reject". SCOPE — that sentence is in the FUTILITY-OF-AMENDMENT analysis, introduced by "Additionally", and follows "the deficiencies cannot be cured by amendment". The Rule 12(b)(6) ground is the Sixteenth Amendment merits — In re Becraft, Brushaber, Wilcox, Stumpf — plus law of the case, "this Court does not sit in a position to review decisions made by the Ninth Circuit". So cite this for AMENDMENT BEING FUTILE BECAUSE THE PLEADING IS SOVEREIGN-CITIZEN RHETORIC, never as a merits holding that the ideology is invalid. This order's parenthetical describing United States v. Mundt, 29 F.3d 233 (6th Cir. 1994) describes Mundt as characterising sovereign-citizen arguments; Mundt's own opinion does not use that term, and rejects the "federal zone" claim.) Kehmeier v. United States, No. CV-24-03211-PHX-SHD, Doc. 26 (D. Ariz. Sept. 24, 2025) (Desai, J.) (the earlier order in the same Kehmeier progression, preceding the Aug. 26, 2026 merits dismissal. "This is yet another case in which Kehmeier has challenged the Government's authority to tax him"; FAC "dismissed without leave to amend", and the court ordered him to "show cause in writing as to why he should not be declared a vexatious litigant" subject to a pre-filing order, observing that "monetary sanctions for such conduct have not sufficiently deterred Kehmeier" and that he has "no appreciation for the limited nature of the federal judicial resources upon which all aggrieved individuals depend" (quoting In re Becraft, 885 F.2d at 549–50) — SCOPE — this is an ORDER TO SHOW CAUSE, not a vexatious-litigant finding. Whether Kehmeier was ever so declared is not established. What is docket-visible is that he filed the next suit on December 8, 2025, after the show-cause deadline, and it reached the merits dismissal entered Aug. 26, 2026. The same order and its 2026 successor together enumerate the prior suits: 2:10-cv-02684 (D. Ariz. May 10, 2011, refund claim called "frivolous"), 2:13-cv-02257 (D. Ariz. Mar. 13, 2014, dismissed and SANCTIONED for bad faith), 2:16-cv-03318 and 2:16-cv-04257 (FOIA suits for records on the taxing authority, both dismissed), suits against two employers over withholding, and two Court of Federal Claims dismissals for lack of jurisdiction, 95 Fed. Cl. 442, 443–44 (2010) and 170 Fed. Cl. 393, 394 (2024).) United States v. Mundt, 29 F.3d 233, 237 (6th Cir. 1994) (Kennedy, J.) (the "federal zone" argument, rejected by a published circuit. Conviction for failing to file returns for 1983 and 1984 under 26 U.S.C. § 7203 AFFIRMED. "[D]efendant argues that the District Court lacked jurisdiction over him because he is solely a resident of the state of Michigan and not a resident of any 'federal zone' and is therefore not subject to federal income tax laws" — held, in the court's own words, "This argument is completely without merit and patently frivolous". Note that is the identical phrase pair Jagim uses, two circuits and two years apart. At 235 the defendant's stated beliefs were that he owed no federal tax because he did not live in a federal zone, was "working for cash as a natural person", and held no privileges; at 237 the court records that "Defendant's position was and continues to be that he is not subject to the federal tax laws". THREE ATTRIBUTION TRAPS. (a) The "silly"/"frivolous" sentence is not the Sixth Circuit's: it, and the "hackneyed tax protester refrain that federal criminal jurisdiction only extends to the District of Columbia, United States territorial possessions and ceded territories", sit inside a block quote from United States v. Collins, 920 F.2d 619, 629 (10th Cir. 1990) — attribute both to Collins. (b) The statute inside that quote is 26 U.S.C. § 7201, Collins's defendant; Mundt was § 7203, failure to file, so do not attribute a tax-evasion conviction here. (c) The opinion contains ZERO instances of "sovereign"; Kehmeier v. United States (D. Ariz. Aug. 26, 2026) describes it as "characterizing sovereign citizen arguments seeking to avoid taxation", which is that court's gloss, not this one's language.).

United States v. Hilgeford, 7 F.3d 1340, 1342 (7th Cir. 1993) (the state-citizenship-as-alienage form, stated compactly by a circuit that had already seen it: "We are again faced with a 'shop worn' argument of the tax protester movement." The defendant "apparently holds a sincere belief that he is a citizen of the mythical "Indiana State Republic" and for that reason is an alien beyond the jurisdictional reach of the federal courts. This belief is, of course, incorrect." Convictions for mail fraud and filing false returns AFFIRMED. The opinion addresses the sincerity of the belief and answers it anyway — the court does not doubt that the belief is held, only that it has any legal effect.).

Rooker v. Fidelity Trust Co., 263 U.S. 413 (1924) and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983) (the two decisions the doctrine is named for, establishing that federal district courts have no appellate jurisdiction to review state-court judgments. SCOPE — neither is a sovereign-citizen case and neither states any view on the ideology; both are cited for the jurisdictional bar alone, and neither should be cited without the narrowing stated in Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280 (2005).).

Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280, 284 (2005) (Supreme Court; the controlling statement of how far that bar actually reaches, and the reason a citation to Rooker or Feldman standing alone overstates it. The doctrine is "confined to cases of the kind from which the doctrine acquired its name: cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments". SCOPE — not a sovereign-citizen case and it states no view on the ideology; cited for the jurisdictional bar alone. The bar reaches only judgments already final when the federal suit began.).

Heck v. Humphrey, 512 U.S. 477, 486-87 (1994) (Supreme Court; the bar met by a damages claim whose success would necessarily imply that a conviction is invalid — "in order to recover damages for allegedly unconstitutional conviction or imprisonment, or for other harm caused by actions whose unlawfulness would render a conviction or sentence invalid, a § 1983 plaintiff must prove that the conviction or sentence has been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such determination, or called into question by a federal court's issuance of a writ of habeas corpus". SCOPE — not a sovereign-citizen case and it states no view on the ideology; cite it for the bar alone. It bars the damages action, not the challenge itself, which lies in habeas, and it does not reach a claim that would leave the conviction undisturbed.).

Patterson v. Jennings, No. 2:25-cv-01081-MHH, Doc. 3 (N.D. Ala. Sept. 21, 2026) (Haikala, J.) (Unpublished district-court screening order — persuasive authority only, not binding precedent, no reporter citation; dismissed under 28 U.S.C. § 1915(e)(2)(B) before service and without an answer, so there is no defended record.) (a State National status claim offered as the reason a judge lacked jurisdiction, and what it does to judicial immunity. Convicted in municipal court of failing to register his "private automobile", the plaintiff sued the two municipal judges, alleging that he had "lawfully declared and documented his status as an Alabama State National, with a U.S. passport card reflecting 5 asterisks," and that the court refused to recognize his objections to jurisdiction. A judge loses absolute immunity for a judicial act only by acting in the "clear absence of all [subject-matter] jurisdiction" (quoting Stump v. Sparkman, 435 U.S. 349, 357 (1978)), and the court held that the claimed status could not supply that absence: "An individual's self-identification as a sovereign citizen does not provide a basis for the individual to challenge a court's jurisdiction." The damages claims against both judges were barred by judicial immunity. SCOPE — the rejection of the ideology is not this court's own: it rests on United States v. Sterling, 738 F.3d 228, 233 n.1 (11th Cir. 2013), so cite Sterling for that proposition and this order only for its application to the clear-absence exception. The court quotes the passport-card allegation but makes no finding about it, so attribute no holding on the asterisks to it. The accompanying vehicle-registration ruling turns on reasonable suspicion for a traffic stop, and the plaintiff's "injured party" argument is not addressed.).

In re Marcantel, No. 3:23-cv-00180-BAJ-EWD (M.D. La. Mar. 31, 2023) (Wilder-Doomes, M.J.) (magistrate judge's report and recommendation), report and recommendation adopted (M.D. La. May 1, 2023) (Jackson, J.) (Unpublished district-court order — persuasive authority only, not binding precedent, no reporter citation.) (a circulating "Affidavit of Truth and Assertory Oath Repudiation and Revocation of Citizenship", declaring "American State National" status, sent by registered mail to the Secretary of State and then filed with the court. The affidavit itself acknowledged that most of the statutory routes to renunciation must be taken abroad, and relied instead on the wartime provision, 8 U.S.C. § 1481(a)(6), which requires a renunciation before the Attorney General's designee and the Attorney General's approval; nothing showed it had been sent to that designee. The court found no authority "for the proposition that a federal district court is the proper entity to receive, or to approve of" a renunciation, and held that "any attempt by Marcantel to renounce his U.S. citizenship by means of filing in this Court is improper and has no legal effect." A citation to 8 U.S.C. § 1101(a)(21) in an accompanying "Declaration of Political Status" fared no better: that provision "is not a method of renunciation" but merely defines "national". Both actions were dismissed with prejudice as frivolous, and the adopting order barred any further filing without a judge's leave and warned that repeated frivolous filings could bring monetary sanctions. SCOPE — the order's general statements about sovereign-citizen theories are quoted from other decisions; cite it for the renunciation holding and the filing restriction only.).

Rodriguez v. Shamburger, No. 1:24-cv-00022 (S.D. Tex. Mar. 5, 2024) (Torteya, M.J.) (magistrate judge's report and recommendation), report and recommendation adopted (S.D. Tex. Apr. 10, 2024) (Unpublished district-court order — persuasive authority only, not binding precedent, no reporter citation.) (the same "Affidavit of Truth and Assertory Oath Repudiation and Revocation of Citizenship", with a "Declaration of Status", offered to create diversity jurisdiction: a plaintiff giving a Texas address claimed to be "a National of the de jure government of the nation state" of the Republic of Texas, and so diverse from a Texas defendant. "But his affidavit and declaration to prove as much have no legal effect." Renunciation requires compliance with 8 U.S.C. § 1481, and outside two inapplicable provisions "no national of the United States can lose United States nationality under this chapter while within the United States" (8 U.S.C. § 1483); both documents were signed in Texas, so he "remains a citizen of the United States and Texas." Dismissed without prejudice for lack of subject-matter jurisdiction, with a warning that refiling the same claims could lead to a preclusion order. SCOPE — a jurisdictional ruling resting on §§ 1481 and 1483, not a frivolousness finding.).

Lawton v. United States, No. 4:19-cv-00173 (S.D. Ga. Jan. 15, 2020) (Ray, M.J.) (magistrate judge's report and recommendation), report and recommendation adopted (S.D. Ga. Apr. 8, 2020) (Baker, J.) (Unpublished district-court order — persuasive authority only, not binding precedent, no reporter citation.) (a 31-page "Declaration of Status" filed as a complaint, asserting a private American citizenship displaced by a centuries-old conspiracy. The court held that the filing "can best be described as legalistic gobbledygook" and that its "language has all the hallmarks of the 'sovereign citizen' theory that has been consistently rejected by the federal courts as an utterly frivolous attempt to avoid the statutes, rules, and regulations that apply to all litigants, regardless of how they portray themselves." "Given the absolute frivolity of plaintiff's filings, his case should be DISMISSED." The report was adopted as the opinion of the court and the complaint dismissed without prejudice under 28 U.S.C. § 1915(e)(2); SCOPE — the authorities the report cites after the "hallmarks" sentence are other courts' words; cite them from their own opinions.).

Phelps v. Obama, No. 1:15-cv-02328 (M.D. Pa. Jan. 27, 2016) (Rambo, J.) (Unpublished district-court memorandum — persuasive authority only, not binding precedent, no reporter citation.) (a pro se plaintiff sought to enforce purported trusts against federal officials and an accounting of federal assets. Denying reconsideration of a dismissal for want of subject-matter jurisdiction, the court described the plaintiff's "prolix and escalatingly bizarre filings" and held that his claims "that he is somehow outside of the purview of the laws of the United States because the United States is acting as a 'temporary military government,' and that his constitutional rights are being abrogated by Defendants' breaches of trusts that Plaintiff has spun from whole cloth", "supported by allegations involving the pope, Jesuits, and terrorists", fell within the Hagans v. Lavine, 415 U.S. 528, 536-37 (1974) standard of claims "so attenuated and unsubstantial as to be absolutely devoid of merit". SCOPE — that standard is the Supreme Court's, quoted here; this court's own holding is that no claim fell within its equity jurisdiction.).

Vega v. United States, No. 24-MC-00262 (MMG) (S.D.N.Y. June 14, 2024) (Garnett, J.) (Unpublished district-court order — persuasive authority only, not binding precedent, no reporter citation.) (a filing seeking "Restoration of Former Status From Being a Public 'United States' citizen" to "A Pre-March 9, 1933, Private Citizen of the United States", lodged as a miscellaneous case on payment of the $52 fee. Held: "The relief that Plaintiff seeks demonstrates that this action is not one of the limited matters where use of the miscellaneous docket is proper"; dismissed without prejudice, with the note that "Plaintiff is not entitled to a refund of the filing fee", a Rule 11 reminder, and a certification that any appeal would not be taken in good faith. SCOPE — a procedural dismissal: the court did not reach the status theory, so cite it for how such a filing is handled, never as a merits ruling on the theory.).

In re Documents from Christopher Daniel Thompson, No. 2:25-mc-00004 (W.D. Pa. Jan. 3, 2025) (Hardy, J.) (Unpublished district-court order — persuasive authority only, not binding precedent, no reporter citation.) (documents filed electronically as a miscellaneous matter, docketed under the titles of a set of status affidavits. The court directed the Clerk "to strike these documents from the record, forthwith, as the documents are not recognized pleadings in any matter", closed the case, and said any new matter must be filed "in accordance with the Local and Federal Rules of Civil Procedure". SCOPE — the order does not describe the documents; their identity comes from the docket's attachment list, so cite it for what the court did with such papers, not for any characterisation of them.).

In re Hovind, 197 B.R. 157, 158-59, 161 (Bankr. N.D. Fla. 1996) (Killian, J.) (Published bankruptcy-court decision — persuasive authority only.) (a debtor who had told the IRS he was "a non resident alien to the federal government" and served an "Asseveration [sic] of Invalid Lien/Levy" claiming to be an inhabitant of the "Florida Republic" filed a Chapter 13 case to recover property the IRS had levied. "The evidence presented at the hearing paints a clear portrait of a tax protester whose sole purpose in seeking relief under chapter 13 was to obtain the release of property seized by the IRS." The court found that the debtor, "who has failed to acknowledge his obligations as a citizen and taxpayer of the United States, seeks to utilize this taxpayer supported court in order to thwart the lawful collection efforts of the Internal Revenue Service", and dismissed the petition for bad faith under 11 U.S.C. § 1307(c) before any plan was considered. SCOPE — a bad-faith dismissal; the status claims are the debtor's words as the court reports them, and the court did not rule on them separately.).

Hovind v. United States, No. 3:20-cv-05484-TKW-MJF (N.D. Fla. June 1, 2021) (Wetherell, J.) (Unpublished district-court order — persuasive authority only, not binding precedent.) (a damages suit by a plaintiff and his ministry against the United States and federal officials, dismissed with prejudice on the magistrate judge's report. The court added that the plaintiffs' objections "demonstrate the frivolous and delusional nature of this suit when, among other things, they assert that" the plaintiff and his ministry "were beyond the jurisdiction of the United States" and that the duty to pay income tax amounted to involuntary servitude. SCOPE — a two-page order adopting the report, whose reasons for dismissal are not quoted here.).

United States v. Hansen, No. 3:05-cv-00921 (S.D. Cal. Dec. 13, 2006) (Lorenz, J.) (amended order entering permanent injunction), aff'd, No. 06-56011, 277 F. App'x 692 (9th Cir. 2008) (Unpublished district-court order; the affirmance is an unpublished memorandum, not precedent under 9th Cir. R. 36-3.) (a civil injunction against a promoter who sold tax-status programs, including a paid program in which customers purportedly gave up their "U.S. citizenship" but kept or claimed "American National citizenship". The court found that "None of these arguments have ever been recognized as legitimately insulating individuals from federal taxation, but instead have been repeatedly rejected by the courts", and that the repudiation program "falsely claims it is possible to renounce one's citizenship to the United States for purposes of avoiding federal income tax liability." It enjoined the "false statements that only federal workers are subject to the Internal Revenue Code, workers need not submit accurate W-4 forms, and that United States citizens are not liable for federal income taxes." On appeal: "The government's motion for sanctions of $8,000 for pursuing a frivolous appeal is granted." SCOPE — a civil injunction under 26 U.S.C. §§ 6700, 6701, 7408 and 7402 against the seller, not a ruling on any customer's filing; the authorities the court quotes for the underlying tax rules are other courts' words.).

United States v. Masat, 948 F.2d 923, 934 (5th Cir. 1991) (published; decided Dec. 3, 1991, rehearing denied Jan. 10, 1992) (tax-evasion conviction AFFIRMED. The defendant argued the district court lacked personal jurisdiction over him: "Masat's brief states he is a 'non-citizen' and a 'non-resident.' More specifically, Masat claims the district court lacked personal jurisdiction over him because he is a 'freeman.'" Held: "In light of the fact that Masat was indicted for tax evasion, appeared before the district court, and has offered this court no support for his lack-of-personal-jurisdiction contention, we find his argument frivolous." Subject-matter jurisdiction was held to rest on 18 U.S.C. § 3231: "It follows that district courts have jurisdiction over Title 26 offenses." SCOPE — a criminal case; the opinion never uses the words "sovereign citizen", and it is cited for the "freeman" / "non-citizen" form of the personal-jurisdiction argument. Later decisions have cited it more broadly, for civil tax-collection suits; the opinion itself does not address those.).

False liens / fraudulent UCC or commercial filings against officials or private parties ("paper terrorism")

United States v. Hart, 701 F.2d 749, 750 (8th Cir. 1983) (per curiam) (common-law liens filed against property owned by IRS employees who audited him, held VOID. Note the posture: this is a CIVIL action for declaratory and injunctive relief brought BY the United States and three named IRS employees — a district director, a group manager and a revenue agent — not a criminal prosecution, despite the caption. After they audited him, Hart recorded with the Register of Deeds "documents styled 'Common-law Liens,' describing certain real property owned by the individual plaintiffs". The district court held those liens "are void and of no legal effect" and enjoined Hart from attempting to "molest, hinder, or impede plaintiffs in the performance of their official duties"; the Eighth Circuit AFFIRMED, held "This appeal is frivolous", and on its own motion imposed "double the costs of appellees, plus a reasonable attorneys' fee" on Hart personally. On appeal his principal argument was that the inferior federal courts have no "civil jurisdiction over a sovereign citizen" — the court answered "We disagree" and pointed to 26 U.S.C. § 7402(a) and 28 U.S.C. §§ 1340, 1345, 1357. That makes this an unusually early PUBLISHED circuit use of the phrase, quoting the litigant's own brief.).

United States v. Greenstreet, 912 F. Supp. 224, 225, 227 (N.D. Tex. 1996) (the underlying action: "the filing of five UCC-1 financing statements against three U.S. Department of Agriculture employees named as 'debtors'", none of whom was ever indebted to the filers; held the burdened employees are not "debtors" within the UCC definition and that "the federal employees named in the financing statements never signed the documents filed against them", a signature generally being necessary for a valid financing statement. The discussion opens with the holding: "Because the purported financing statements fail to comply with the requisites of law, they are void and of no legal consequence." Summary judgment for the United States GRANTED, the statements declared void).

United States v. Studley, 783 F.2d 934, 937 & nn.3, 6 (9th Cir. 1986) (CRIMINAL tax appeal — conviction on three counts of willful failure to file returns under 26 U.S.C. § 7203 AFFIRMED. At 937 the court held the contention "that she is not a 'taxpayer' because she is an absolute, freeborn and natural individual" to be "frivolous", because "An individual is a 'person' under the Internal Revenue Code and thus subject to 26 U.S.C. § 7203". THE SANCTIONS LANGUAGE IS FOOTNOTE DICTA AND CONDITIONAL: n.3 observes the argument "has been consistently and thoroughly rejected by every branch of the government for decades" and that "advancement of such utterly meritless arguments is now the basis for serious sanctions imposed on civil litigants who raise them", and n.6 adds that such claims "would be grounds for sanctions if raised in a civil suit". The opinion NEVER names Rule 11 or any other rule, and no sanction was imposed on Studley — do not cite it as Rule 11 authority).

United States v. Jones, 65 F.4th 926, 930 (7th Cir. 2023) ("sovereign-citizen theories are not just 'bizarre,' . . . they also reflect misunderstandings about criminal jurisdiction" (citation omitted)).

Monroe v. Beard, 536 F.3d 198, 203 n.4 (3d Cir. 2008) (per curiam) (prison officials could confiscate UCC, redemption, and name-copyrighting materials as contraband because they facilitate fraudulent liens against officials; n.4 records that under the scheme "inmates are encouraged to file liens against correctional officers and other prison officials in order to extort their release from prison"). 18 U.S.C. § 1521 (false liens against certain officers).

Smith v. NCB Management Services, No. 2:26-cv-01439-CFK (E.D. Pa. Sept. 21, 2026) (Kenney, J.) (Unpublished district-court screening memorandum — persuasive authority only, not binding precedent, no reporter citation; dismissed under 28 U.S.C. § 1915(e)(2)(B)(i) at screening, before service and without an answer, so there is no defended record.) (the private-party form of the instrument, and the only entry here in which the lien is quoted in full. Rather than an official, the target was the furnisher reporting a debt on the claimant's credit file. Styling herself "Trustee" of a trust bearing her own name, and naming the collection company as "Lien Holder", she served a notice asserting a lien on her own assets and demanding: "NO ASSETS OR MONEY CAN BE Recouped until the lien of $1,000,000.00 is PAID IN FULL to the Cynthia Smith Revocable Living Trust." The notice then set its own penalty for silence — "If you violate this notice by NO RESPONSE, CONTINUE TO REPORT the Listed Assets" or write back refusing, "you now opt in to paying Cynthia Smith Revocable Living Trust" — and when the company kept reporting, she sued for the million dollars. Held frivolous and dismissed WITH PREJUDICE, leave to amend refused as futile: the complaint was dismissed "as factually and legally frivolous". A claim under the Fair Credit Reporting Act failed because nothing alleged the statutory dispute-and-investigation sequence that alone supports a private action against a furnisher under 15 U.S.C. § 1681s-2(b), and a Contracts Clause claim failed twice over, because "NCB is a private bank and not a state actor" and because "Smith has not alleged any change in state law nor an impaired contractual relationship". SCOPE — cite this for a self-written lien against a private company, and for a notice whose own terms purport to convert non-response into consent; it is a screening dismissal of one pro se complaint, not a considered treatment of lien law, and 18 U.S.C. § 1521 has no application where the target is not a federal officer. The court applied the sovereign-citizen description although the filer never claimed it, noting that she "does not identify herself as a sovereign citizen" while her allegations "manifest the features of the sovereign citizen theory" — a characterisation reached from the document's features, and one the court supported by a string cite to cases not read here.).

United States v. Creation Sci. Evangelism, No. 3:12-cv-00136-MCR-EMT (N.D. Fla. June 27, 2012) (Rodgers, C.J.) (Unpublished district-court order — persuasive authority only, not binding precedent.) (after real property was forfeited to satisfy a criminal money judgment, a non-lawyer claiming to direct the former owners' ministry and property trusts recorded liens on the forfeited parcels. On default, the court declared the liens "null and void ab initio", directed that the order be filed in the county land records, and permanently enjoined the defendants and their agents from filing "new notices of lien, indebtedness, claims or purported liens" on any forfeited property without leave of court. As an alternative ground, it found that "the purpose for filing the liens was to hinder the government's ability to sell the property as directed in the earlier order." SCOPE: a default judgment whose primary ground is res judicata; cite it for voiding and enjoining liens that cloud a court-ordered sale, not as a contested ruling on lien law.).

Hodson v. Moore, No. 2:15-cv-00453 (S.D. Tex. Sept. 23, 2016) (Libby, M.J.) (ECF No. 103) (Unpublished order of a magistrate judge presiding by consent — persuasive authority only, not binding precedent, no reporter citation.) (a state prisoner was disciplined for filing false financial liens against prison staff, and sued the officers who searched his cell and conducted the hearing. Using secured-party instructions seized from his cell, he had served on two officers "proofs of claim" "that purport to overturn his disciplinary conviction if Defendants fail to respond to his correspondence within three days and to place a lien on Defendants' real and personal property". The court found that he "prepared and filed false U.C.C. paperwork in 2012" and that "Inmate Hodson filed fraudulent liens against" the two officers, held that his "claims against Defendants concerning his disciplinary conviction and the punishments he received are barred by Heck" until the conviction is set aside, and dismissed the rest with prejudice, ordering that "this dismissal count as a 'strike'" under 28 U.S.C. § 1915(g); SCOPE — a prisoner civil-rights case: it addresses the consequences of a lien campaign inside a prison, not lien law generally.).

Fee schedules / contract by entry / commercial affidavit demands against officials

United States v. James, 328 F.3d 953, 954-56 (7th Cir. 2003) (Easterbrook, J.) (name-copyright fee demands against court officers: adherents "hand out what they call 'security agreements' that purport to oblige strangers to pay hefty sums for using the members' names, which they deem copyrighted under their private legal system", and "James demanded that the prosecutor, witnesses, and judge enter into compensation contracts before James would acknowledge the court's authority". Held "Laws of the United States apply to all persons within its borders"; conviction AFFIRMED).

United States v. Studley, 783 F.2d 934, 937 & nn.3, 6 (9th Cir. 1986) (CRIMINAL tax appeal — conviction on three counts of willful failure to file returns under 26 U.S.C. § 7203 AFFIRMED. At 937 the court held the contention "that she is not a 'taxpayer' because she is an absolute, freeborn and natural individual" to be "frivolous", because "An individual is a 'person' under the Internal Revenue Code and thus subject to 26 U.S.C. § 7203". THE SANCTIONS LANGUAGE IS FOOTNOTE DICTA AND CONDITIONAL: n.3 observes the argument "has been consistently and thoroughly rejected by every branch of the government for decades" and that "advancement of such utterly meritless arguments is now the basis for serious sanctions imposed on civil litigants who raise them", and n.6 adds that such claims "would be grounds for sanctions if raised in a civil suit". The opinion NEVER names Rule 11 or any other rule, and no sanction was imposed on Studley — do not cite it as Rule 11 authority).

Attorneys and judges as foreign agents, BAR guild members, or holders of a title of nobility

United States v. Kriemelmeyer, No. 3:07-cr-00052-bbc (W.D. Wis. Nov. 20, 2007) (Crabb, J.) (the foreign-agent form of the argument, reached directly and disposed of in two sentences. Moving to quash his indictment and conviction, the defendant argued that "officers of the court acted in collusion as unregistered foreign agents". Held: "This allegation is too implausible to require comment." The order denied the motion along with the defendant's other filings and directed that the court "will not entertain any additional filings" of that kind. SCOPE, and read it before citing this — the sentence is a summary refusal to engage, of the same shape as Jagim's, and not reasoned analysis. It is authority that the foreign-agent theory got nowhere, not authority about the Foreign Agents Registration Act, about who may be admitted to practise, or about the status of any bar association. It says nothing whatever about the titles-of-nobility theory, which is a distinct claim that happens to travel with this one. PIN: the passage is on page 3 of the five-page order; no reporter citation exists for it.).

No Contract / Contract Rejection Scripts

United States v. Pryor, 842 F.3d 441 (6th Cir. 2016) (defendant repeatedly asserted "no contracts with the United States corporation," refused consent, and treated the court's Faretta colloquy as an "offer to contract"; court identified the rhetoric as sovereign-citizen ideology and rejected the jurisdictional challenge, though the published holding centers on Faretta/self-representation waiver and affirmance of conviction rather than on contract-rejection scripts).