[DO NOT PUBLISH]

In the

United States Court of Appeals

For the Eleventh Circuit

____________________

No. 22-12905

Non-Argument Calendar

____________________

USA, 

Plaintiff-Appellee,

versus

JOVON MONTELL HOLLOWELL, 

Defendant-Appellant.

____________________

Appeal from the United States District Court

for the Northern District of Georgia

D.C. Docket No. 1:21-cr-00239-JPB-JKL-1

____________________

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2 Opinion of the Court 22-12905

Before NEWSOM, GRANT, and TJOFLAT, Circuit Judges.

PER CURIAM:

JoVon Hollowell, proceeding pro se, appeals his convictions 

for dealing firearms without a license and making false statements 

to a federally licensed firearms dealer. Hollowell argues that the 

court did not have jurisdiction over him because he is a citizen of 

the Cherokee Nation rather than the United States, citing the Major Crimes Act.1 He also contends that he was not tried by a jury 

of his peers, as the jury did not consist of his fellow tribal members. 

We hold that the District Court had jurisdiction, and we affirm 

Hollowell’s convictions.

I.

On June 15, 2021, a federal grand jury charged Hollowell in 

a three-count indictment. Count one charged Hollowell with dealing firearms without a license, in violation of 

18 U.S.C. §§ 922(a)(1)(A), 923(a), and 924(a)(1)(D). Counts two and 

three charged Hollowell with making false statements to a federally licensed firearms dealer, in violation of 18 U.S.C. §§ 922(a)(6)

and 924(a)(2). The indictment alleged that Hollowell violated the 

statutes in Clayton County, Georgia, which is in the Northern District of Georgia. Following a hearing, the District Court permitted 

Hollowell to represent himself pro se with standby counsel.

1 See 18 U.S.C. § 1153.

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22-12905 Opinion of the Court 3

Hollowell later filed a document that the District Court construed as a motion to dismiss for lack of jurisdiction. There, he 

summarily argued that the court lacked jurisdiction. The District 

Court denied the motion, finding that there was jurisdiction based 

on the indictment.

During jury selection, Hollowell moved for a mistrial because the jury did not consist of his peers, as none of the jurors 

were Indigenous. The Government argued that there was no legal 

basis for a mistrial, and the District Court denied the motion.

At trial, the Government called Benjamin Southall. Southall 

testified that he worked for the Bureau of Alcohol, Tabaco, and 

Firearms (“ATF”), investigating violations of federal firearms laws. 

Southall added that he witnessed Hollowell buy firearms from Arrowhead Pawn in Clayton County, Georgia.

The Government also admitted a receipt for firearms Hollowell bought from Arrowhead Pawn. Additionally, the Government admitted an ATF Form 4473 “Firearms Transaction Record” 

that Hollowell completed with each firearm that he purchased—

which federal firearms licensees are required to obtain before transferring a firearm to a purchaser. On the form, Hollowell stated that

he was a U.S. Citizen, lived in Dunwoody, Georgia, and answered 

“yes” in the fields asking whether he was the actual transferee or 

buyer of the firearm. The Government also admitted text messages that showed Hollowell had coordinated with potential customers about meeting to buy the firearms he had purchased from 

Arrowhead Pawn.

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Collectively, the evidence demonstrated that Hollowell 

made false statements when he purchased sixteen firearms over a 

two-month period with intent to resell the firearms for profit. The 

jury found Hollowell guilty on all counts.

After the trial, Hollowell filed multiple documents arguing 

that the court lacked jurisdiction due to his Indigenous nationality 

of the Cherokee Nation. At his sentencing hearing, Hollowell 

again objected that the court lacked jurisdiction over him as a citizen of the Cherokee Nation. Further, he contended that the jury 

did not consist of his peers. The District Court overruled Hollowell’s objections and it imposed a total sentence of forty-six months’ 

imprisonment followed by three years of supervised release. Hollowell timely appealed.

II.

We review questions of statutory subject matter jurisdiction 

de novo. United States v. Grimon, 923 F.3d 1302, 1305 (11th Cir. 2019).

III.

Although he makes multiple conclusory arguments, all of 

Hollowell’s arguments rely on the same premise: the District 

Court did not have jurisdiction because he is a citizen of the “Tsalagi Cherokee Nation” and did not commit any offense under the 

Major Crimes Act, 18 U.S.C. § 1153. Hollowell also asserts that he 

was not tried by a jury of his peers because the jury did not consist 

of fellow tribal members. We disagree.

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District courts have jurisdiction to hear cases involving “all 

offenses against the laws of the United States.” 18 U.S.C. § 3231. 

“[A]n indictment charging that a defendant violated a law of the 

United States gives the district court jurisdiction over the case . . . .” 

McCoy v. United States, 266 F.3d 1245, 1252 (11th Cir. 2001). And 

“[a] federal district court has personal jurisdiction to try any defendant brought before it on a federal indictment charging a violation 

of federal law” in its district. United States v. Rendon, 354 F.3d 1320, 

1326 (11th Cir. 2003).

As to Hollowell’s main contention, the District Court had 

both subject matter and personal jurisdiction. The indictment 

charged Hollowell with violating federal laws—dealing in firearms 

without a license and making false statements to a federally licensed firearms dealer—based on his firearm purchases from Arrowhead Pawn in suburban Atlanta. As we have previously noted, 

“[s]ubject matter jurisdiction in every federal criminal prosecution 

comes from 18 U.S.C. § 3231. . . . That’s the beginning and the end 

of the jurisdictional inquiry.” McCoy, 266 F.3d at 1252 n.11 (omission in original) (quoting Hugi v. United States, 164 F.2d 378, 380 

(7th Cir. 1999)). Thus, Hollowell’s status as a Native American is 

irrelevant.2

2 Although Hollowell does not explicitly refer to himself as a “sovereign citizen,” he asserts that the District Court lacked jurisdiction because he is a “natural man.” We have summarily rejected “so called ‘sovereign citizen[]’” theories as frivolous. Cantu v. City of Dothan, 974 F.3d 1217, 1223 n.2 (11th Cir. 

2020) (quoting United States v. Sterling, 738 F.3d 228, 233 n.1 (11th Cir. 2013)).

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Likewise, Hollowell’s invocation of the Major Crimes Act is 

immaterial. The Major Crimes Act applies to crimes committed 

“within . . . Indian country.” 18 U.S.C. § 1153(a). Indian country

includes “all land within the limits of any Indian reservation under 

the jurisdiction of the United States Government.” Id. § 1151. Suburban Atlanta does not meet that definition. See McGirt v. Oklahoma, 140 S. Ct. 2452, 2459, 207 L. Ed. 2d 985 (2020) (noting that 

the “key question” under the Major Crimes Act is whether an offense was committed in Indian country).

Finally, Hollowell has abandoned any argument that he was 

not tried by a jury of his peers. Although we construe pro se filings 

liberally, “this leniency does not give a court license to serve as de 

facto counsel for a party or to rewrite an otherwise deficient pleading in order to sustain an action.” United States v. Padgett, 

917 F.3d 1312, 1317 (11th Cir. 2019) (quoting GJR Invs., Inc. v.

County of Escambia,132 F.3d 1359, 1369 (11th Cir. 1998)). Hollowell’s filing fails to point to any law or supporting authority for this 

argument. At best, Hollowell’s assertion is based on his sovereign 

citizen argument, which this Court has summarily rejected as frivolous. See United States v. Sterling, 738 F.3d 228, 233 n.1 (11th Cir. 

2013). And “simply stating that an issue exists, without further argument or discussion, constitutes abandonment of that issue and 

precludes our considering the issue on appeal.” Singh v. U.S. Att’y 

Gen., 561 F.3d 1275, 1278 (11th Cir. 2009) (per curiam); see also Timson v. Sampson, 518 F.3d 870, 874 (11th Cir. 2008) (“[I]ssues not 

briefed on appeal by a pro se litigant are deemed abandoned.”). 

Hollowell, thus, has abandoned this issue.

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Accordingly, we hold that the District Court had jurisdiction

and we affirm Hollowell’s conviction.

AFFIRMED.

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