Sovereign citizen

The **sovereign citizen movement** is a loose grouping of American and Commonwealth litigants, commentators, tax protesters, and financial-scheme promoters. Self-described "sovereign citizens" see themselves as answerable only to their particular interpretation of the common law and as not subject to any government statutes or proceedings. In the United States, they do not recognize U.S. currency and maintain that they are "free of any legal constraints". They especially reject most forms of taxation as illegitimate. Participants in the movement argue this concept in opposition to the idea of "federal citizens", who, they say, have unknowingly forfeited their rights by accepting some aspect of federal law. The doctrines of the movement resemble those of the freemen on the land movement more commonly found in the Commonwealth, such as in Britain and in Canada.

Many members of the sovereign citizen movement believe that the United States government is illegitimate. JJ MacNab, who writes for *Forbes* about anti-government extremism, has described the sovereign-citizen movement as consisting of individuals who believe that the county sheriff is the most powerful law-enforcement officer in the country, with authority superior to that of any federal agent, elected official, or local law-enforcement official. The movement can be traced back to white-extremist groups like Posse Comitatus and the constitutional militia movement. It also includes members of Moorish sects.

The Federal Bureau of Investigation (FBI) classifies some sovereign citizens ("sovereign citizen extremists") as domestic terrorists. In 2010 the Southern Poverty Law Center (SPLC) estimated that approximately 100,000 Americans were "hard-core sovereign believers", with another 200,000 "just starting out by testing sovereign techniques for resisting everything from speeding tickets to drug charges".

In surveys conducted in 2014 and 2015, representatives of U.S. law enforcement ranked the risk of terrorism from the sovereign-citizen movement higher than the risk from any other group, including Islamic extremists, militias, racists, and Neo-Nazis. The New South Wales Police Force in Australia has also identified sovereign citizens as a potential terrorist threat.

## Theories

Writing in *American Scientific Affiliation*, Dennis L. Feucht reviewed *American Militias: Rebellion, Racism & Religion* by Richard Abanes, and described the theory of Richard McDonald, a sovereign-citizen leader, which is that there are two classes of citizens in America: the "original citizens of the states" (or "States citizens") and "U.S. citizens". McDonald asserts that U.S. citizens or "Fourteenth Amendment"

> citizens have civil rights, legislated to give the freed black slaves after the Civil War rights comparable to the unalienable constitutional rights of white state citizens. The benefits of U.S. citizenship are received by consent in exchange for freedom. State citizens consequently take steps to revoke and rescind their U.S. citizenship and reassert their *de jure* common-law state citizen status. This involves removing one's self from federal jurisdiction and relinquishing any evidence of consent to U.S. citizenship, such as a Social Security number, driver's license, car registration, use of ZIP codes, marriage license, voter registration, and birth certificate. Also included is refusal to pay state and federal income taxes because citizens not under U.S. jurisdiction are not required to pay them. Only residents (resident aliens) of the states, not its citizens, are income-taxable, state citizens argue. And as a state citizen landowner, one can bring forward the original land patent and file it with the county for absolute or allodial property rights. Such allodial ownership is held "without recognizing any superior to whom any duty is due on account thereof" (*Black's Law Dictionary*). Superiors include those who levy property taxes or who hold mortgages or liens against the property.
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In support of his theories, McDonald has established State Citizen Service Centers around the United States as well as a related web presence.

Writer Richard Abanes asserts that sovereign citizens fail to sufficiently examine the context of the case laws they cite, and ignore adverse evidence, such as Federalist No. 15, where Alexander Hamilton expressed the view that the Constitution placed everyone personally under federal authority.

Some sovereign citizens also claim that they can become immune to most or all laws of the United States by renouncing their citizenship, a process they refer to as "expatriation", which involves filing or delivering a nonlegal document claiming to renounce citizenship in a "federal corporation" and declaring only to be a citizen of the state in which they reside, to any county clerk's office that can be convinced to accept it.

## History

The concept of a sovereign citizen originated in 1971 in the Posse Comitatus movement as a teaching of Christian Identity minister William P. Gale. The concept has influenced the tax protester movement, the Christian Patriot movement, and the redemption movement—the last of which claims that the U.S. government uses its citizens as collateral against foreign debt.

Gale identified the Fourteenth Amendment to the United States Constitution as the act that converted "sovereign citizens" into "federal citizens" by their agreement to a contract to accept benefits from the federal government. Other commentators have identified other acts, including the Uniform Commercial Code, the Emergency Banking Act, the Zone Improvement Plan, and the alleged suppression of the Titles of Nobility Amendment.

In addition to Gale's white-nationalist origins, their sovereign arguments have been adopted by the **Moorish sovereigns**. Their beliefs may have derived, in part, from the Moorish Science Temple of America which has condemned the sovereign citizen ideologies. The underpinnings of the theories of African-American exemption vary. The Washitaw Nation claims rights through provisions in the Louisiana Purchase treaty granting privileges to Moors as early colonists and the non-existent "United Nations Indigenous People’s Seat 215".

Some of those in the movement believe that the term "sovereign citizen" is an oxymoron and prefer to label themselves as individuals "seeking the Truth".

## Legal status of theories

Individuals have tried to use "sovereign citizen" arguments in U.S. federal tax cases since the 1970s. Variations of the argument that an individual is not subject to various laws because the individual is "sovereign" have been rejected by the courts, especially in tax cases such as *Johnson v. Commissioner* (Phyllis Johnson's argument—that she was not subject to the federal income tax because she was an "individual sovereign citizen"—was rejected by the court), *Wikoff v. Commissioner* (argument by Austin Wikoff—that he was not subject to the federal income tax because he was an "individual sovereign citizen"—was rejected by the court), *United States v. Hart* (Douglas Hart's argument—in response to a lawsuit against him for filing false lien notices against Internal Revenue Service personnel, that the U.S. District Court had no jurisdiction over him because he was a "sovereign citizen"—was rejected by the District Court and the United States Court of Appeals for the Eighth Circuit), *Young v. Internal Revenue Service* (Jerry Young's argument—that the Internal Revenue Code did not pertain to him because he was a "sovereign citizen"—was rejected by the U.S. District Court), and *Stoecklin v. Commissioner* (Kenneth Stoecklin's argument—that he was a "freeborn and sovereign" person and was therefore not subject to the income tax laws—was rejected by the United States Court of Appeals for the Eleventh Circuit; the court imposed a $3,000 penalty on Stoecklin for filing a frivolous appeal). See also *Missett v. Commissioner* and *Hyslep v. Commissioner*.

In *Risner v. Commissioner*, Gregg Risner's argument—that he was not subject to federal income tax because he was a "Self-governing Free Born Sovereign Citizen"—was rejected by the court as being a "frivolous protest" of the tax laws. See also *Maxwell v. Snow* (Lawrence Maxwell's arguments—that he was not subject to U.S. federal law because he was a "sovereign citizen of the Union State of Texas", that the United States was not a republican form of government and therefore must be abolished as unconstitutional, that the Secretary of the Treasury's jurisdiction was limited to the District of Columbia, and that he was not a citizen of the United States—were rejected by the court as being frivolous), and *Rowe v. Internal Revenue Service* (Heather Rowe's arguments — that she was not subject to federal income tax because she was not a "party to any social compact or contract", because the IRS had no jurisdiction over her or her property, because she was "not found within the territorial limited jurisdiction of the US", because she was a "sovereign Citizen of the State of Maine", and because she was "not a U.S. Citizen as described in 26 U.S.C. 865(g)(1)(A) . . ."—were rejected by the court and were ruled to be frivolous).

Other tax cases include *Heitman v. Idaho State Tax Commission*, *Cobin v. Commissioner* (John Cobin's arguments—that he had the ability to opt out of liability for federal income tax because he was white, that he was a "sovereign citizen of Oregon", that he was a "non-resident alien of the United States", and that his sovereign status made his body real property—were rejected by the court and were ruled to be "frivolous tax-protester type arguments"), *Glavin v. United States* (John Glavin's argument—that he was not subject to an IRS summons because, as a sovereign citizen, he was not a citizen of the United States—was rejected by the court), and *United States v. Greenstreet* (Gale Greenstreet's arguments—that he was of "Freeman Character" and "of the White Preamble Citizenship and not one of the 14th Amendment legislated enfranchised De Facto colored races", that he was a "white Preamble natural sovereign Common Law De Jure Citizen of the Republic/State of Texas", and that he was a sovereign, not subject to the jurisdiction of the United States District Court—were ruled to be "entirely frivolous"). In view of such cases, the IRS has added "free born" or "sovereign" citizenship to its list of frivolous claims that may result in a $5,000 penalty when used as the basis for an inaccurate tax return.

Similarly, when Andrew Schneider was convicted and sentenced to five years in prison for making a threat by mail, Schneider argued that he was a free, sovereign citizen and therefore was not subject to the jurisdiction of the federal courts. That argument was rejected by the United States Court of Appeals for the Seventh Circuit as having "no conceivable validity in American law".

In a criminal case in 2013, the U.S. District Court for the Western District of Washington noted:

> Defendant [Kenneth Wayne Leaming] is apparently a member of a group loosely styled "sovereign citizens". The Court has deduced this from a number of Defendant's peculiar habits. First, like Mr. Leaming, sovereign citizens are fascinated by capitalization. They appear to believe that capitalizing names have some sort of legal effect. For example, Defendant writes that "the REGISTERED FACTS appearing in the above Paragraph evidence the uncontroverted and uncontrovertible FACTS that the SLAVERY SYSTEMS operated in the names UNITED STATES, United States, UNITED STATES OF AMERICA, and United States of America ... are terminated nunc pro tunc by public policy, U.C.C. 1-103 ..." (Def.'s Mandatory Jud. Not. at 2.) He appears to believe that by capitalizing "United States", he is referring to a different entity than the federal government. For better or for worse, it's the same country.
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> Second, sovereign citizens, like Mr. Leaming, love grandiose legalese. "COMES NOW, Kenneth Wayne, born free to the family Leaming, [date of birth redacted], constituent to The People of the State of Washington constituted 1878 and admitted to the union 22 February 1889 by Act of Congress, a Man, "State of Body" competent to be a witness and having First Hand Knowledge of The FACTS ..." (Def.'s Mandatory Jud. Not. at 1.)
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> Third, Defendant evinces, like all sovereign citizens, a belief that the federal government is not real and that he does not have to follow the law. Thus, Defendant argues that as a result of the "REGISTERED FACTS", the "states of body, persons, actors and other parties perpetuating the above-captioned transaction(s) [i.e., the Court and prosecutors] are engaged ... in acts of TREASON, and if unknowingly as victims of TREASON and FRAUD ..." (Def.'s Mandatory Jud. Not. at 2.)
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> The Court, therefore, feels some measure of responsibility to inform Defendant that all the fancy legal-sounding things he has read on the internet are make-believe ...
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Defendant Kenneth Wayne Leaming was found guilty of three counts of retaliating against a federal judge or law enforcement officer by a false claim, one count of concealing a person from arrest, and one count of being a felon in possession of a firearm. On May 24, 2013, Leaming was sentenced to eight years in federal prison.

In challenges to laws requiring driver's licenses, defendants have unsuccessfully asserted that, as sovereign citizens, there is an inalienable right to drive on highways. Albert Kouba argued this after he was convicted of driving while suspended. The Supreme Court of North Dakota rejected his argument and upheld his conviction.

In Australia there have been a few minor cases where parties have invoked arguments surrounding the "sovereign man". All of these arguments have failed before Australian courts. The courts in New Zealand also appear to have rejected the "sovereign man" arguments.

### Filing of false lien notices

According to *The New York Times*, cases involving so-called sovereign citizens pose "a challenge to law enforcement officers and court officials" in connection with the filing of false notices of liens—a tactic sometimes called "paper terrorism". Anyone can file a notice of lien against property such as real estate, vehicles, or other assets of another under the Uniform Commercial Code and other laws. In most states of the United States, the validity of liens is not investigated or inquired into at the time of filing. Notices of liens (whether legally valid or not) are a cloud on the title of the property and may affect the property owner's credit rating, ability to obtain home equity loans, refinance the property or take other action with regards to the property. Notices of releases of liens generally must be filed before property may be transferred. The validity of a lien is determined by further legal procedures. Clearing up fraudulent notices of liens may be expensive and time-consuming. Filing fraudulent notices of liens or documents is both a crime and a civil offense.

## Incidents

Oklahoma City bombing conspirator Terry Nichols, who was convicted in 2004, was a member of the sovereign citizen movement, having asserted individual sovereignty in at least three court cases.

### 2010

In May 2010, two police officers in West Memphis, Arkansas, were shot and killed by Joseph T. Kane after Kane and his father were the subject of a traffic stop. Kane and his father were later identified as members of the sovereign citizen movement. In a final armed confrontation with the police, the Kanes were killed.

In September 2010, David Russell Myrland, an associate of a sovereign citizens group, sent emails and placed telephone calls to various officials of the City of Kirkland, Washington, telling them to "keep their doors unlocked", that they were going to be arrested, and that they "should not resist". Myrland also reportedly threatened federal judges and the chief prosecutor of King County, Washington. Myrland's threat to arrest the mayor of Kirkland came about after he was arrested by police. His vehicle had been impounded after he was found driving with a suspended license and expired vehicle-license tags. An unloaded gun with ammunition nearby had been found on the seat of the car. Although he was not a law enforcement officer, Myrland had claimed that he had the authority to form a group of private citizens to arrest felons in public office "as permitted by RCW 9A.16.020" (the state statute governing the lawful use of force). On December 2, 2011, Myrland was sentenced to three years and four months in federal prison after pleading guilty in connection with the threats he made, including the threat to arrest the mayor of Kirkland, Washington. While in prison, he submitted a civil lawsuit without the required filing fee, accusing the government of civil rights violations, claiming that the criminal complaint against him was "babbling-collusion-threats" and "backwards-correct-syntaxing-modification fraud". Myrland was released from prison on January 29, 2014.

### 2011

In March 2011, a central figure in the sovereign citizen movement named Samuel Lynn Davis pleaded guilty to 31 counts of money laundering in Federal district court in Nevada. Davis was snared in a sting operation after he agreed to launder more than $1.29 million in what he believed to be illicit funds. Davis accepted $73,782 in fees to launder the money, not realizing he was dealing with federal law enforcement agents. In October 2011, Davis was sentenced to four years and nine months in federal prison, and was ordered to pay over $95,000 in restitution. As of late July 2012, Davis was classified as a fugitive, having failed to surrender to authorities to begin his prison sentence in June 2012. On August 7, 2012, Davis was arrested by sheriff's deputies in White Earth, North Dakota. and was scheduled for release from prison on April 24, 2017.

On November 4, 2011, a federal jury in Montgomery, Alabama, found Monty Ervin guilty of conspiracy to defraud the United States and tax evasion. His wife Patricia Ervin was also found guilty of various related charges. According to a news release by the U.S. Department of Justice, Ervin and his wife had acquired hundreds of investment properties over a ten-year period, had received more than $9 million in rental income, but had paid nothing in federal income taxes. The Ervins reportedly claimed that they were not United States citizens, that they were "sovereigns", and that they did not consider themselves subject to federal or state law. Ervin and his wife had also filed documents in probate court attempting to renounce their U.S. citizenship. In one filing, Ervin declared himself to be the governor of Alabama in its "original jurisdiction". On May 29, 2012, Monty Ervin was sentenced to ten years in prison, and Patricia Ervin was sentenced to five years of probation, with the condition that she spend 40 consecutive weekends in jail.

In December 2011, Shawn Talbot Rice was arrested at his home at Seligman, Arizona, after a ten-hour standoff with FBI agents and other law enforcement personnel. On July 24, 2012, Rice was found guilty in federal court in Nevada in connection with the same money-laundering scheme that resulted in the conviction of Samuel Lynn Davis. The guilty verdicts came on one count of conspiracy to commit money laundering, thirteen counts of money laundering, and four counts of failure to appear in court in connection with time that Rice spent as a fugitive. Rice, who had also falsely claimed to be a lawyer and a rabbi, was described as "a leader in the anti-government 'sovereign citizens' movement'". During the trial, Rice tried to argue that the presiding federal judge had no authority to render a judgment against Rice. On March 20, 2013, Rice was sentenced to 8 years and 2 months in prison, and was ordered to forfeit over $1.29 million. As of early June 2014, Rice is incarcerated at the Florence Federal Correctional Institution at Florence, Colorado, and is scheduled for release on October 9, 2020.

In 2011, Malcolm Roberts sent a bizarre affidavit to then Australian Prime Minister Julia Gillard demanding to be exempt from the carbon tax and using language consistent with the "sovereign citizen" movement. Roberts became a senator following the Australian federal election, 2016; however, he was subsequently found to be ineligible for election.

### 2012

On February 1, 2012, Timothy Garrison, an accountant from Mount Vernon, Washington, was sentenced to three and a half years in federal prison after having pleaded guilty to tax fraud. He admitted to having filed about 50 falsified tax returns. Federal prosecutors contended that Garrison's actions cost the IRS over 2.4 million dollars in tax revenues. Prosecutors also stated that the sixty-year-old accountant had described himself as a "sovereign citizen" beyond the reach of state and federal law. Garrison had previously served time in federal prison in the 1980s in connection with fraud against investors in a cattle ranch. Garrison was released from Federal prison on July 16, 2014.

On June 18, 2012, Schaeffer Cox, who had asserted that he was a sovereign citizen, was found guilty in the United States District Court in Anchorage, Alaska, of several felony charges including conspiracy to commit murder. On January 8, 2013, Cox was sentenced to 25 years and 10 months in prison.

On June 20, 2012, Anson Chi was arrested by federal authorities for allegedly trying to blow up a natural gas pipe line in a residential area of Plano, Texas. On June 3, 2013, Chi pleaded guilty to a charge of attempting to destroy a natural gas pipeline used in interstate commerce, and to a charge of possessing an explosive device not registered with the National Firearms Registration and Transfer Record. However, on February 26, 2014, the U.S. District Court for the Eastern District of Texas issued an order granting Chi's motion to withdraw his guilty plea. Eventually, he again pleaded guilty and, on June 11, 2015, he was sentenced to twenty years in federal prison for possession of an unregistered firearm and for malicious use of an explosive.

On July 19, 2012, Martin Jonassen, who had described himself as a sovereign citizen, was found guilty by a jury in an Indiana federal court of kidnapping his 21-year-old daughter, whom he allegedly had sexually abused, and of obstruction of justice. During the incident, the daughter escaped from a hotel room where Jonassen had been holding her, ran naked into a store and begged for help. Jonassen was caught on surveillance footage chasing her, dragging her out of the store and pushing her into his car. The daughter reportedly "had never been to school and only read books about religion, history and the government approved by her father." She had seen a doctor only once in her life. On February 19, 2013, Jonassen was sentenced to forty years in federal prison. Jonassen is incarcerated at the United States Penitentiary at Tucson, Arizona, and is scheduled for release on August 10, 2047.

On August 16, 2012, two sheriff's deputies were shot to death and two others seriously wounded after having been ambushed near LaPlace, Louisiana. Authorities arrested seven suspects, two of whom have been identified by law enforcement as members of a sovereign citizen's group.

On August 27, 2012, Lonnie G. Vernon and Karen Vernon, an Alaskan couple who were described as "followers of Schaeffer Cox", pleaded guilty to conspiracy to commit murder of U.S. District Judge Ralph Beistline, who presided over a federal income tax case based on sovereign-citizen theories which had cost the Vernons their house. They also admitted that they had planned to kill Beistline's daughter and grandchildren, and an IRS official. The Vernons bought a silencer-equipped pistol and hand grenades in March 2011; but the seller to whom they disclosed their plans was a confidential informant, and the Vernons were arrested as soon as the transaction had been consummated. At the sentencing hearing on January 7, 2013, Lonnie Vernon continued to assert that he was denying the authority of the court, the judge and the prosecutors. Karen Vernon was sentenced to 12 years in prison. Lonnie Vernon was sentenced to over 25 years in prison. Lonnie Vernon is incarcerated at a Federal prison facility at Terre Haute, Indiana, and is scheduled for release on October 26, 2033. Karen Vernon is incarcerated at a Federal prison facility at Waseca, Minnesota, and is scheduled for release on September 4, 2021.

On September 10, 2012, David B. Graham of Gwinnett County, Georgia, pleaded guilty to a violation of the Georgia racketeering statute. After losing his home in a foreclosure, he moved back into the home and filed a fraudulent quitclaim deed in the county property records in an attempt to transfer the ownership of the home back to himself. He was one of approximately a dozen so-called "sovereign citizens" who had been indicted on racketeering charges "for essentially stealing 18 high-end homes in eight counties...." At the hearing, Graham's attorney disclosed to the Court that Graham had been "influenced by the sovereign citizen group – individuals who believe that they each make up their own sovereign state or nationality, and are thus immune to federal, state and local laws...."

On September 18, 2012, James Timothy ("Tim") Turner was arrested after having been indicted by a federal grand jury in Alabama on one count of conspiracy to defraud the United States under 18 U.S.C. § 371 by, among other things, allegedly filing a false 300 million dollar bond in an attempt to pay taxes, one count of passing a false 300 million dollar bond, five additional counts of violations of section 514(a)(2) of title 18 of the U.S.C. (relating to fictitious documents), one count of filing false Form 1096 reports with the IRS, one count of willful failure to file a federal income tax return, and one count of giving false testimony in a federal bankruptcy proceeding. Turner had described himself as the "president" of a sovereign citizens group called the "Republic for the United States of America". According to the Southern Poverty Law Center, Turner had also been involved with the Guardians of the Free Republics organization. On March 22, 2013, Turner was found guilty on all charges. On July 31, 2013, he was sentenced to 18 years in Federal prison. He is incarcerated at the Federal Correctional Institution at Oakdale, Louisiana, and is scheduled for release in May 2028.

On September 27, 2012, 71-year-old Phillip Monroe Ballard, who at the time was being held in Federal custody in Fort Worth, Texas, facing a trial on federal tax charges scheduled to begin on October 1, 2012, was charged with offering $100,000 in a plot to kill U.S. District Judge John McBryde, the judge who was scheduled to preside over the trial. Federal authorities alleged that Ballard gave a fellow inmate detailed instructions to kill Judge McBryde with a high-powered rifle from a building across the street from the federal courthouse. Ballard allegedly said the killer could shoot the judge as he entered the courthouse. The FBI also alleged that Ballard had a backup plan to have his accomplice plant a bomb in the judge's vehicle. Ballard's tax trial did not begin on Monday, October 1. Instead, Ballard appeared for a preliminary hearing on the murder solicitation charge on that day. The investigation reportedly had begun a few weeks earlier, following a tip from a fellow inmate. Ballard, who claimed to be a "sovereign citizen" immune from all U.S. laws, was convicted in 1987 of a federal tax charge in connection with his seizure by force of a Mercedes automobile that was subject to a federal tax lien. In 2011, Ballard was also charged with falsely holding himself out as an attorney. On December 11, 2013, Ballard was found guilty of attempting to hire a hit man to kill the federal judge. On March 17, 2014, Ballard was sentenced to the maximum 20 years in prison for the solicitation to commit murder conviction under 18 U.S.C. § 373. Ballard had been awaiting trial on one count of corrupt interference with the U.S. internal revenue laws under 26 U.S.C. § 7212 and six counts of aiding and assisting in the preparation of false and fraudulent U.S. federal income tax returns under 26 U.S.C. § 7206. Those charges were dropped, however, after Ballard's sentencing in the murder solicitation case. Ballard is scheduled for release in December 2029.

On December 11, 2012, Jeniffer Herring of Myrtle Beach, South Carolina, allegedly led officers on a chase of up to 70 miles per hour while she was talking by cell phone to a 911 dispatcher as she allegedly refused to stop for the police who were trying to apprehend her. According to a news release from the Brunswick County Sheriff's Office, Herring told 911 dispatchers she would pull over for deputies for $300,000. A law enforcement official indicated that Herring was a member of the "sovereign citizen" movement. Herring eventually was stopped and was charged with driving while intoxicated, felony flight to elude arrest, driving with a revoked driver license, reckless driving, and driving left of center. Herring also faces a separate charge for failure to appear in court in another case involving a charge of driving while intoxicated. On January 28, 2013, she was indicted by a grand jury.

On December 29, 2012, dentist Glenn Unger, alias "Dr. Sam Kennedy," was arrested in Ogdensburg, New York, after having been indicted by a federal grand jury ten days earlier, on one count of attempting to interfere with the administration of the internal revenue laws under Internal Revenue Code section 7212(a), four counts of filing false claims for tax refunds under 18 USC section 287, one count of tax evasion under Internal Revenue Code section 7201, and one count of uttering a fictitious obligation under 18 USC section 514(a)(2). He was charged with filing more than $36 million in fraudulent federal income tax refund claims. On January 2, 2013, a federal prosecutor asserted in a court hearing for Unger that Unger was a danger to the community and that Unger had stated that he would rather die than become subject to the government. Unger has been identified as a leader of the sovereign citizen movement. The indictment alleged, among other things, that in June 2011 Unger submitted false documents with the Clerk's Office of Saratoga County, New York, in an attempt to release a $116,410.43 federal tax lien against him, for taxes and penalties for years 2004, 2005, and 2006.

The FBI began looking at Unger in the spring of 2010, in connection with the now-defunct group called the Guardians of the Free Republics, when the FBI was investigating letters that had been sent by that group to the governors of all fifty states, demanding that all governors resign within three days. Prosecutors also alleged that Unger filed no valid federal income tax returns between 1999 and 2005. On May 23, 2013, the court ordered a mental competency hearing for Unger after he referred to himself as being "deceased." On August 7, 2013, the Court ruled that Unger was competent to stand trial. After a four-day trial Unger was found guilty of all charges by a jury in Federal court in Albany, New York, on October 21, 2013. Evidence in the case also indicated that Unger left his dental business in 2006, and referred about eighty of his patients to an orthodontist, William O'Donnell, without telling O'Donnell that the patients had already pre-paid Unger for dental work. After O'Donnell complained to Unger that the customers were expecting O'Donnell to perform the work, Unger reportedly gave O'Donnell a bogus promissory note that O'Donnell could supposedly use to obtain funds from the U.S. Department of the Treasury. When O'Donnell tried to deposit the note at a bank, he found the note to be fictitious and worthless. On April 21, 2014, Unger was sentenced to eight years in federal prison. Unger is incarcerated at a Federal prison facility at Allenwood, Pennsylvania, and is scheduled for release on February 6, 2020.

### 2013

In May 2013, the Criminal Investigation Division of the IRS, issued its *Annual Business Report* for the Fiscal Year 2012 (for the fiscal year ended September 30, 2012). Within the "Narcotics and Counterterrorism" section of the report, in a portion entitled "Sovereign Citizens", the IRS mentions the convictions of Monty and Patricia Ervin, Timothy Garrison and David Russell Myrland. In the report, the IRS states: "During 2012, CI [the Criminal Investigation division of the IRS] found a re-emergence of individuals and/or entities who proclaimed themselves Sovereign Citizens. Generally, they utilized anti-government or anti-tax rhetoric schemes to disrupt the tax administration process. CI has partnered with Department of Justice and Office of the Inspector General for Tax Administration to create a working group to address this emerging threat."

On June 14, 2013, Raymond Leo Jarlik Bell was sentenced in the U.S. District Court for the Western District of Washington to 8 years and one month in prison after having been convicted of five counts of filing false, fictitious, and fraudulent claims; 15 counts of assisting in filing false U.S. federal tax returns, three counts of mail fraud; and one count of criminal contempt. Bell and his wife Ute Christine Jarlik Bell (who was also convicted) were identified by the FBI as being members of the sovereign citizen movement. In a news media release, U.S. Attorney Jenny A. Durkan stated that Bell had "held himself out as a tax expert with contacts at the IRS—when both the IRS and a federal judge told him repeatedly that his conduct was criminal..." Durkan stated that Bell believed he was above the law and that Bell had promoted a fraudulent tax refund scheme known as "OID fraud." Bell's wife, Ute Christine Jarlik Bell, was convicted of four counts of filing false, fictitious and fraudulent claims.

On August 22, 2013, David Allen Brutsche and Devon Campbell Newman were arrested for plotting to abduct, torture and kill Las Vegas police officers in order to attract attention to the sovereign citizens movement. They reportedly attended sovereign citizen philosophy training sessions, bought guns, and found a vacant house for their activities. The two allegedly planned to torture and kill police officers and are alleged to have created videos explaining their actions and why officers had to die. On December 12, 2013, Devon Newman pleaded guilty to a lesser charge, conspiracy to commit false imprisonment, and was sentenced to one year of probation. The trial for Brutsche was scheduled to begin March 10, 2014 but, on February 3, 2014, Brutsche pleaded guilty to conspiracy to kidnap a police officer. On April 7, 2014, he was sentenced to five years probation.

In November 2013, Robert Carr seized eleven Ohio homes while their owners were away and filed quiet title suits to the properties. The grand jury later indicted him on felony charges of breaking and entering, and theft. Carr was sentenced to seven months in prison.

### 2014

On January 9, 2014, 67-year-old Sharon Alicia Anzaldi of Elmwood Park, Illinois was sentenced in federal court to five years in prison for filing fraudulent tax returns. She filed false returns for herself, family and friends, and had claimed tax refunds of over $8 million. She had tried to have her case dismissed on various grounds, including the theory that, although she was a citizen of Illinois, she was not subject to federal criminal law. The U.S. District Court ruled against her arguments. Anzaldi was also ordered to pay over $851,000 in restitution to the IRS. Anzaldi is currently an inmate at a Federal Bureau of Prisons facility at Lexington, Kentucky, and was scheduled for release on September 19, 2018.

On February 13, 2014, a former chiropractor named John A. Glavin of New Lisbon, Wisconsin was sentenced in Federal district court in Wisconsin to three years in prison followed by three years of supervised release. Glavin was found guilty of filing fraudulent federal income tax refund claims of over $956,000. When the IRS investigated his false tax refund claims, Glavin filed false liens against IRS personnel and against the Secretary of the Treasury. In addition to his federal tax problems, Glavin had problems under the laws of the State of Wisconsin by using a "Sovereign Citizens Movement" scheme in connection with a bank foreclosure of his home. While still awaiting trial on the federal charges of filing the false tax refund claims, Glavin sent false promissory notes to the bank. He claimed that the U.S. Treasury would pay off his home mortgage. As a result of that scheme, Glavin was sentenced in a Juneau County Court in Wisconsin to 90 days in jail for fraud. In the Juneau County Court, Glavin was ordered to pay restitution of over $44,000 to the bank and to refrain from filing "sovereign citizen" paperwork in any court. The judge in the Juneau County Court stated, "The sovereign citizen theory is foolish... It is legal nonsense and frivolous." Glavin is incarcerated at Federal Medical Center Rochester, at Rochester, Minnesota, and is scheduled for release on June 11, 2016.

In March 2014, after Cliven Bundy lost a second U.S. District Court case in a 20-year court battle, he sent letters entitled *"Range War Emergency Notice and Demand for Protection"* to county, state, and federal officials. In his court filings, depositions, and subsequent statements, he said he does not recognize the U.S. government because he is a citizen of the state of Nevada. In media interviews, Bundy used the language of the sovereign citizen movement as a rallying call, beckoning support from members of the Oath Keepers, the White Mountain Militia, the Praetorian Guard, and other like-minded individuals to join his Bundy militia in a fight against the U.S. government. Armed militants from Nevada, Idaho, Arizona, California, and other areas responded with a show of force by joining the Bundy militia at a heavily armed militia camp near Bunkerville, Nevada in early April 2014. Approximately 1000 militia members and supporters joined the fight. On April 12, 2014, and consistent with the sovereign citizen credo and without success, Bundy ordered Sheriff Gillespie to confront the federal agents, disarm them and deliver their arms to them within an hour of his declaration.

In April 2014, Mark Manuel, of Franklin, Tennessee, who set up a consultancy business claiming to be able to remove debts by accessing secret government bank accounts, was convicted with two associates on eight counts of mail fraud. In a press release, the FBI stated that, "the men defrauded hundreds of thousands of dollars from more than 250 victims. Witnesses testified that the men encouraged customers to seek cash advances from credit cards and to raid retirement accounts in order to pay Eden Gifted Properties' fees."

On June 6, 2014, Dennis Marx, who was later identified as being a member of the sovereign citizens movement, opened fire on a Forsyth County, Georgia courthouse, injuring one deputy before being shot and killed himself. Marx had become involved in a dispute with sheriff's deputies in 2011. He had been arrested on marijuana and weapons possession charges. As a result, Marx sued the sheriff's department for alleged civil rights violations and use of excessive force. The Southern Poverty Law Center asserts that in the suit, Marx filed documents using the pseudo-legal language common to "sovereign citizen" court actions. On the day of the incident, Marx had been scheduled to enter a plea at the courthouse in connection with the year 2011 arrest that had resulted in his lawsuit.

On June 18, 2014, Cherron Phillips (who sometimes calls herself "River Tali El Bey") was found guilty by a Federal court jury in Chicago on ten counts of retaliatory filing of false claims, including 100 billion dollars in false lien notices, against various government officials, apparently in connection with her brother's conviction on drug conspiracy charges in 2008. Even as the jury was deliberating her own case, Phillips had claimed that the court had no jurisdiction over her. After the guilty verdict was announced, U.S. District Court Judge Michael Reagan referred to her as a "paper terrorist," and the United States Marshal took her into custody. On October 14, 2014, she was sentenced to seven years in federal prison. Phillips is a resident of the Federal Correctional Institution at Waseca, Minnesota, and is scheduled for release on August 20, 2020.

### 2015

Already in prison since January 2007 for failure to pay federal taxes, for structuring various bank transactions to evade reporting requirements, and for attempting to obstruct administration of the U.S. internal revenue laws, Young Earth Creationist and Sovereign Citizen proponent Kent Hovind had a raft of new charges laid against him for the filing of lis pendens liens on property deemed forfeited to pay for earlier unpaid taxes. The government argued that the filing of these liens had been earlier forbidden by a court. During his incarceration, Hovind relied increasingly on Sovereign Citizen arguments, denying his U.S Citizenship and declaring "Democracy is evil and contrary to God's law". Hovind's co-defendant was Paul J. Hansen, another Sovereign Citizen advocate. In filings before the court relating to the trial, both made lengthy submissions recycling typical Sovereign Citizen tropes, such as "withdrawing consent for the proceedings", denial of jurisdiction, invocation of maritime law, the attempted convocation of unsanctioned citizen grand juries, and which threatened the judge personally. While the jury failed to reach a verdict on the other charges, on March 12, 2015, Hovind was found guilty of criminal contempt. The judge, however, rendered a judgment of acquittal in favor of Hovind on May 18, 2015, concluding that the relevant court order had lacked specific language prohibiting Hovind from doing what he did. Hansen, who claims he is neither a U.S. citizen nor resident because he lives on "church land", was convicted on two counts of contempt and sentenced to 18 months in prison and three years probation of August 21, 2015.

In January 2015, Ishaq Ibrahim, 28, of Philadelphia was convicted in a court in Montgomery County, Pennsylvania, of multiple counts of conspiracy and robbery after defending himself using sovereign citizen arguments. Ibrahim, charged with bank robbery, repeatedly questioned the validity of the proceedings and the jurisdiction of the judge during the trial, and asserted he did not consent to the proceedings. Ibrahim initially represented himself at the trial, but after he became disruptive and was removed from the courtroom, the judge appointed lawyers to represent him. Ibrahim then monitored the trial via video from another room.

In Miami, Florida in 2015, forty-year old E-Yage Bowens was sentenced to 485 years in prison for repeatedly raping a sixteen-year-old girl and forcing her to cut herself. Bowens claimed to be a "sovereign citizen", and to be immune from U.S. laws.

### 2016–2017

On December 13, 2016, Markeith Loyd allegedly shot and killed his girlfriend, Sade Dixon, and then fled the scene. On January 9, 2017, Orlando Police Lt. Debra Clayton was alerted to Loyd's presence at a Walmart on John Young Parkway. Officer Clayton attempted to arrest Loyd, and Loyd allegedly shot and killed the lieutenant. Markeith Loyd was successfully arrested on January 17, 2017 after being located in the Orlando Carver Shores area. On March 1, 2017, Loyd appeared in an Orange County court where he said, "For the record, I want to state that I am Markeith Loyd. Flesh and blood. I'm a human being. I'm not a fictitious person. I'm not a corporation." He went on to say, "And therefore, I am going to tell you the fact, I am in due court, I accept the charges value. And I want to use my UCC financial statement, my number, to write these charges off." The officiating judge, Chief Judge Frederick J. Lauten, ended up assigning Loyd a standby lawyer "because [he] believes Loyd believes he is a sovereign citizen." On March 16, 2017, Florida Governor Rick Scott replaced Ninth Judicial Circuit State's Attorney Aramis D. Ayala with State Attorney Brad King as the prosecutor of the state's case against Markeith Loyd due to Ayala's decision to not seek the death penalty against Loyd.

On April 12, 2017, Austin, Texas police seized three guns and over 1,000 rounds of ammunition from Steven Thomas Boehle who had been planning an attack.

In November 2017, convicted sex offender and former Subway spokesman Jared Fogle filed a motion to overturn his convictions by stating that the federal court did not have jurisdiction to convict him because of his status as a "sovereign citizen." His motion was dismissed as "frivolous."

### 2018

On April 22, 2018, Travis Reinking, who police said had several past confrontations with authorities and had shown signs of mental instability, carried out a mass shooting in a Nashville Waffle House in which four people were killed and four were wounded. A bag containing a handwritten identification card with his name was found. In July 2017, he had been arrested in Washington D.C. after confronting an officer at the security barrier outside the White House, saying he needed to talk to the president and that "he was a sovereign citizen and has a right to inspect the grounds". According to Mark Pitcavage, it is unlikely that he was a "legit sovereign citizen", considering factors like that he did not self-represent himself in court and did not write his name and address in legalese. He concludes that mental illness must have played an important role in the attack.

On the night of October 19, 2018, ten days after Hurricane Michael had heavily damaged Mexico Beach, Florida, the Citrus County Sheriff's Department announced that they, in conjunction with the Bay County Sheriff's Office, had arrested six people "dressed in tactical clothing", armed with AR15s and pistols, and wearing bulletproof vests, who had claimed to be federal agents. The announcement said that the Sheriff's Department had "learned the suspects were Sovereign Citizens," and they were arrested on various weapons charges and for impersonating a law enforcement officer.

## U.S. government responses

Following the 1995 Oklahoma City bombing, Congress passed the Antiterrorism and Effective Death Penalty Act of 1996, enhancing sentences for certain terrorist-related offenses.

In October 2015, during a domestic terrorism seminar at George Washington University, National Security Division leader and Assistant Attorney General, John P. Carlin, stated that the Obama Administration had witnessed "anti-government views triggering violence throughout America". Carlin personally confirmed the 2014 START survey findings, saying that during his time at the FBI and DOJ, law enforcement officials had identified sovereign citizens as their top concern. Carlin referred to social media as a "radicalization echo chamber", through which domestic extremists deliver, re-appropriate and reinforce messages of hate, propaganda, and calls to recruitment and violence. He charged its service providers with the responsibility of tracking and taking action against, any such abuse of its services.

Carlin announced that, in order to ensure that the DOJ benefited from terrorist-related information and input received from around the country, it had created a new position of Domestic Terrorism Counsel. He said the position would serve several functions: as the main point of contact for U.S. Attorneys working on domestic terrorism matters; to ensure proper coordination of domestic terrorism cases; to play a key role in DOJ headquarter-level efforts to identify domestic terrorism trends, and to analyze legal gaps or enhancements, in order to better shape department strategies for countering national security threats; and to help direct DTEC efforts by providing members with overview and insights into various domestic terrorism cases and trends.

## Notable people self identifying as sovereign citizens

* Edward and Elaine Brown
* Jared Fogle
* John Joe Gray