[Cite as State v. Farley, 2013-Ohio-5517.]

COURT OF APPEALS 

MUSKINGUM COUNTY, OHIO 

FIFTH APPELLATE DISTRICT 

STATE OF OHIO 

 Plaintiff-Appellee 

-vsDONNA FARLEY 

 Defendant-Appellant 

JUDGES: 

Hon. Sheila G. Farmer, P. J. 

Hon. John W. Wise, J. 

Hon. Patricia A. Delaney, J. 

Case Nos. CT2013-0026 and 

 CT2013-0029 

O P I N I O N 

CHARACTER OF PROCEEDING: Criminal Appeal from the County Court, 

Case Nos. CRB 1300218 and CRB 

1300091 

JUDGMENT: Affirmed 

DATE OF JUDGMENT ENTRY: December 16, 2013 

APPEARANCES: 

For Plaintiff-Appellee For Defendant-Appellant 

D. MICHAEL HADDOX DONNA FARLEY 

PROSECUTING ATTORNEY 7811 Poverty Ridge 

27 North Fifth Street, Suite 2 Blue Rock, Ohio 43720 

Zanesville, Ohio 43701 
Muskingum County, Case No. CT2013-0026 and CT2013-0029 2

Wise, J. 

{¶1} Appellant Donna Farley appeals her conviction and sentence on multiple 

counts of Dog at Large, entered in the Muskingum County Court following a plea of no 

contest. 

{¶2} Appellee is the State of Ohio. 

STATEMENTS OF FACTS AND CASE

{¶3} On January 31, 2013, Defendant-Appellant Donna J. Farley was charged 

with nine (9) counts of Dog at Large, in violation of R.C. §955.22. (See CRB 1300091). 

{¶4} Appellant was arraigned on February 13, 2013, at which time she entered 

a plea of No Contest, and the case was scheduled for sentencing August 20, 2013. 

{¶5} Subsequently, on March 13, 2013, Appellant was charged with five (5) 

new counts of Dog at Large, in violation of R.C. §955.22. (See CRB 1300218). 

{¶6} On April 22, 2013, Appellant appeared for trial. Prior to trial, Appellant 

engaged in a dialogue with the trial court, arguing that certain Uniform Commercial 

Code (UCC) resolutions stripped the trial court of jurisdiction over her. 

{¶7} The trial court treated Appellant’s arguments as a motion challenging the 

court’s jurisdiction over her and denied the motion. Appellant then proceeded to enter a 

plea of No Contest. The trial court found Appellant guilty and sentenced her in both 

cases to fines and costs on each count. 

{¶8} Appellant now appeals, setting forth the following Assignment of Error:

ASSIGNMENT OF ERROR

{¶9} “I. APPELLANT'S CONVICTION OF DOG AT LARGE R.C.955.22 (14 

COUNTS) WAS IN VIOLATION OF THE NEW, LEGAL, LAWFUL AND UNREBUTTED 
Muskingum County, Case Nos. CT2013-0026 and CT2013-0029 3

UCC FILINGS (UNIFORM COMMERCIAL CODE) THAT HAVE CANCELLED 

GOVERNMENT CHARTERS.” 

I. 

{¶10} In her sole Assignment of Error, Appellant argues that the trial court did 

not have jurisdiction over her in this matter. We disagree. 

{¶11} In her pro se brief, Appellant maintains that she “never gave her consent 

to be governed.” Appellant cites to a blank, five-page document captioned “Courtesy 

Notice” which appears to be the product of “The One People’s Public Trust”. Appellant 

argues that such document provided the trial court with information of “the new legal, 

lawful and unrebutted landscape ushered in last year with the UCC filings”. 

{¶12} We note that similar “sovereign citizen” arguments have been raised in 

various federal court actions by pro se litigants, albeit unsuccessfully. See, e.g., United 

States v. Benabe, 654 F.3d 753, 767 (7th Cir.2011) (“Regardless of an individual's 

claimed status of descent, be it as a ‘sovereign citizen,’ a ‘secured-party creditor,’ or a 

‘flesh-and-blood human being,’ that person is not beyond the jurisdiction of the courts”). 

{¶13} Furthermore, “the U.C.C. has no bearing on criminal subject matter 

jurisdiction.” United States v. Mitchell, 405 F.Supp.2d 602 (D.Md.2005). See also Van 

Hazel v. Luoma, E.D.Mich. No. 05–CV–73401–DT (Oct. 27, 2005) (noting that other 

courts have rejected similar jurisdictional claims as frivolous, and holding that “Petitioner 

cannot divest the State of Michigan of jurisdiction to prosecute him of a criminal offense 

simply by declaring a security interest in himself pursuant to the Uniform Commercial 

Code”). 
Muskingum County, Case Nos. CT2013-0026 and CT2013-0029 4

{¶14} Upon review, we find no legal authority to support Appellant’s arguments 

and find the trial court did not err in dismissing her motion and entering a finding of 

guilty upon her pleas of no contest. 

{¶15} For the foregoing reasons, the judgment of the County Court of 

Muskingum County, Ohio, is affirmed. 

By: Wise, J. 

Farmer, P. J., and 

Delaney, J., concur. 

 ___________________________________ 

 HON. JOHN W. WISE 

 ___________________________________ 

 HON. SHEILA G. FARMER 

 ___________________________________ 

 HON. PATRICIA A. DELANEY 

JWW/d 1118 
Muskingum County, Case No. CT2013-0026 and CT2013-0029 5

IN THE COURT OF APPEALS FOR MUSKINGUM COUNTY, OHIO 

FIFTH APPELLATE DISTRICT 

STATE OF OHIO : 

 : 

 Plaintiff-Appellee : 

 : 

-vs- : JUDGMENT ENTRY 

 : 

DONNA FARLEY : 

 : 

 Defendant-Appellant : Case Nos. CT2013-0026 and 

: CT2013-0029 

 For the reasons stated in our accompanying Memorandum-Opinion, the 

judgment of the County Court of Muskingum County, Ohio, is affirmed. 

 Costs assessed to Appellant. 

 ___________________________________ 

 HON. JOHN W. WISE 

 ___________________________________ 

 HON. SHEILA G. FARMER 

 ___________________________________ 

 HON. PATRICIA A. DELANEY