sovereign citizen wins in courtsovereign citizen wins in court
RICO laws were originally drafted to fight organized crime but now are sometimes applied to other forms of criminal enterprise. [61] See Sovereign Citizens Movement, supra note 13. The burdens Sovereigns place on court time is not limited to their motion practice antics. Just like with Q-Anon, followers of an anonymous figure Q who revealed purported secrets about the government and global elite,[60] it can be easy to dismiss sovereign citizens as irrational conspiracy theorists. [17] See id. [38] See Richard L. Nygaard, Crime, Pain and Punishment: A Skeptics View, 102 Dickinson L. Rev. v. Varsity Brands, Inc. An individual who believes he is above the law, and that he only has to. These defendants truly believe they answer only to themselves. [54] Reed v. Stein, No. [14] See Francis X. Sullivan, Note, The Usurping Octopus of Jurisdictional/Authority: The Legal Theories of the Sovereign Citizen Movement, 1999 Wis. L. Rev. R. Civ. [72] This approach targets both attorneys and pro se litigants that have met specific criteria, neutralizing the inevitable argument that restrictions on sovereign citizens are tantamount to discrimination based on political philosophy and creed. Anyone got a follow up? Harder to dismiss are the effects these conspiracy theorists have on the legal system, where simple court cases can be tied up for months as sovereign citizens file thousands of documents, overwhelming prosecutors, public defenders, and judges. There is an argument to be made that restricting sovereign citizens from engaging in paper terrorism is contrary to a persons fundamental right to access to justice. The Flagship Publication of Penn State Law, I, me, Pauline from the house of Bauer challenge the courts [sic] jurisdiction over me, a living woman, one of we the people, creator of Government.[1] So begins a ramblingand often incoherent114-page notice to the United States District Court for the District of Columbia. Hosted by Dan Abrams, each episode includes interviews with judges, witnesses, and victims who give a first-hand account of what really happened during these intense courtroom moments. [25], Admittedly, the explanation above is a vast oversimplification of the beliefs of the sovereign citizen movement. [6] See Bauer Notice, supra note 1, at 7. 1106, 1129 (questioning the deterrent impact on the litigiousness of those who do not believe in the validity of the government to begin with). [30], Sovereign citizen arguments often, but not always, include religious elements. 'Paper terrorism' endobj
Mr. Beeks, you should be quiet unless spoken to.[57], The presence of so many putative sovereign citizens at the Capitol Riot suggests that sovereign citizens have found a home with the far right in American politics. [23] Sovereign Citizens Movement, supra note 13; see also Caesar Kalinowski IV, A Legal Response to the Sovereign Citizen Movement, 80 Mont. The most troubling thing about SovCits is that they seem to be determined to shoot themselves in the foot. The Intelligence Report is the SPLC's award-winning magazine. There Holly Christensen is a first-year J.D. See supra note 9 and accompanying text. States such as Illinois have relied on this solution, enacting legislation heightening penalties for frivolous filings. B. Assn J. They're annoying. [58] See Gino Spocchia, QAnon Merges with White Extremists and Spreads New Conspiracy Trump Will Be President Again on March 4, The Independent, (Jan. 26, 2021, 1:56 PM), https://bit.ly/3vcaMrz. Visit us at aetv.com for more info. [69] March-Safborn, supra note 64, at 11314. In 1996, the population of Algorta was 35,600. Sovereigns believe that the American government set up by the founding fathers, under a common-law legal system, was secretly replaced. Republican state Rep. Richard Marple is scheduled to introduce a bill that treats sovereign citizens as a recognized legal class, and proposes a $10,000 fine for state agencies that don't buy . Average prices of more than 40 products and services in Algorta,Basque country,Spain, Spain. [71] Most states has passed some version of a vexatious litigant statute; the statutes usually involve specific standards that, once satisfied, are met with punishments ranging from fines to prohibition from taking legal action. If and when a court manages to negotiate Sovereign litigants plethoric filings to hold an actual hearing, the unfortunate presiding judge can expect a barrage of outlandish pseudo legalese, often from agitated individuals. (July 5, 2021), https://www.justsecurity.org/77328/sovereign-citizens-more-than-paper-terrorists/ [https://perma.cc/SH98-JLKF] (describing the ideological overlap between Sovereign Citizens and anti-maskers). uMLL^R[pCd#Dv^7jv4A 0:)srd4)0^UOg5KL1)^Y6?xz%Ib 9Iib+|?mM#z^B(~`Jt +(:hd7N2"$ [49] More importantly though, pre-filing injunctions are often akin to closing the stable door after the horse has bolted. ; see also Christine Sarteschi, Sovereign Citizens: More Than Paper Terrorists, Just Sec. [46] Some proponents of the movement argue that all laws and amendments to the Constitution after the 1871 passage of the Fourteenth Amendment are invalid due to complex legal arguments involving the citizenship portion of the amendment. [65] See March-Safborn, supra note 64, at 46. In one of the first cases of its kind, 12 sovereigns in North Georgia charged with stealing properties worth millions of dollars including mansions and a strip mall in Atlanta's wealthy Buckhead neighborhood are being prosecuted under the Racketeer Influenced and Corrupt Organizations (RICO) Act. [47] The benefits of pre-filing injunctions are obvious; they remove the Sovereign Citizens favorite weapon from their arsenal by requiring a judge to sign off on any filings proposed by the pro se litigant. No obligation to pay a traffic or speeding ticket. Beane was sentenced to 13 years in prison, 5 years of supervised release, and was ordered to pay over $550,000 in restitution. [39] See Goode, supra note 35 (discussing liens filed against the district attorney in Gadsden, Alaska, and describing dealing with these liens as nightmarish). [45] Sovereign Citizens Movement, supra note 13 (Galactic Sovereigns . [54] See Loeser, supra note 40, at 1137 (advocating for soft solutions to the Sovereign Citizen problem, such as procedural and economic reform). )f)/ hG!;6OGNM)Dj9h~(J# =HN5"%C3z!yIE%J,oLLd{;Wwm
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Zf*b%&Tk=.L1|&FO(/R'Qo!Gt{DqSx2yY]A.yNydcC2O4MDFUle 229 19th Ave. South hold a concurrent belief that friendly aliens will visit earth and they are actively planning for this occurrence or believe that public officials and other individuals are reptilian aliens.). [41] See Mastrony, supra note 10, at 102627. [30] See S. Poverty L. The term "sovereign citizen" refers to an individual who does not agree with a particular law and will find any means of justifying his noncompliance with that law. [7] See Id. In February, a Sarasota, Fla., homicide detective, Tom Laughlin, was fired after renouncing his U.S. citizenship and claiming he was no longer subject to federal law and not required to pay taxes. [34] See, e.g., DMV Hearing Featuring Sovereign Citizen Marc Stevens, supra note 25 (repeatedly challenging the applicability of the states laws to the defendant). The Georgia property theft cases are only the most recent manifestation of a movement that has swelled rapidly in the last two years, affecting most major law enforcement agencies. The Sovereign belief system. Algorta. Whether its the networks distinctive brand of award-winning disruptive reality, groundbreaking documentary, or premium scripted drama, A\u0026Es brave storytelling always makes entertainment an art. Related: Sovereign Citizen Gets Tased Trying To Enter Courtroom Ultimately, the most effective solution would be to remedy our countrys systemic flaws that result in gross legal and economic disparities and form the recruitment pool of disenfranchised citizens which Sovereign leaders can exploit. National cabinet encourages wearing masks to combat COVID-19. But Pete Barns green shirt sure does . Denver airline pilot Jack Wharton Thomas, who had argued that his income didn't qualify as taxable "wages," was sentenced in January to 10 years' probation for tax evasion and fraud. In fact, some journalists have suggested that sovereign citizen belief systems have merged with Q-Anon conspiracy theories, creating crossover between the two conspiracies. [41] Other sovereign citizens result to violence and chaos. 1013, 1013, 1015 (2016). [2], The Sovereign Citizen movement originally emanated as an offshoot of far-right political groups such as Posse Comitatus in the early 1970s. use a patchwork of misinterpreted old English law, constitutional text and Bible verses to form pseudo-courts, which they call common law courts, or entirely new governments, which they describe as assemblies.). Create an account to follow your favorite communities and start taking part in conversations. The sovereign citizen movement is a loose grouping of litigants, activists, tax protesters, financial scheme promoters and conspiracy theorists, who claim to be answerable only to their. Minneapolis, MN 55455, Tel: (612) 625-9330 Additionally, he had shared one of Tucci-Jarrafs posts on his Facebook page a few days prior to flaunt his newfound wealth. She received her Bachelor of Arts in Political Science from Brigham Young University. [49] See Mastrony, supra note 10, at 1018; see also United States v. Cheek, 882 F.2d 1263, 1268 n.2 (7th Cir. x;ms3T d'b=ihKv}"$C,bwYV>lbUF?>n~{T}G//]H$U;d*)R'y_K;~b}c7H Beane, who worked as a computer programmer, insisted on the witness stand that it never crossed his mind to research this claim online to validate it. [10] Moorish Sovereign Citizens adhere to the notion that the 1787 Moroccan American Treaty of Friendship placed all of those with Moroccan descent on an equal footing with the U.S. government. A Clayton County, Ga., SWAT team in March evicted sovereign citizens Gideon and Deborah Israel from a home they had occupied for more than a year, after the couple flooded the county with fraudulent paperwork seeking to block their eviction. From left to right: Ulster County "sovereign citizens" Ed Parenteau, Jeffrey Burfeindt and Richard Ulloa, Local Policing and Immigration Enforcement, Request for Legal Assistance Economic Justice, bogus liens and fraudulent invoices totaling $1.24 trillion. [12] The grossly disparate nature of the two groups practices and world views means that they might as well be (and often actually are) speaking different languages. [44] Furthermore, recognized Sovereign leaders have demonstrated a steadfastness to their beliefs, even when it results in personal legal difficulties. [26]The precise methodology employed by Sovereign Citizens is best explored through illustrative case studies. [1] 13, 2010), https://bit.ly/3jrLf8t. The sovereign citizen movement does not even recognize U.S. currency as real money. 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[15] See, e.g., Anna Harman, Recent Vaccine Mandates Raise Questions and Controversy Over Constitutional Rights, Cedars (Oct. 2, 2021), https://cedars.cedarville.edu/2021/10/recent-vaccine-mandates-raise-questions-and-controversy-over-constitutional-rights/ [https://perma.cc/Z9PJ-6BC4] (discussing whether schools, businesses, and governments have the authority to issue vaccine requirements). This is because they believe the U.S. government, and the laws it creates, is illegitimate, and as such they reject most forms of taxation. [66] See March-Safborn, supra note 64, at 46. Depending on the particular strain and variant of the sovereign citizen, details of the governments timing, motivation, and purpose vary. https://www.splcenter.org/fighting-hate/extremist-files/ideology/sovereign-citizens-movement, https://cedars.cedarville.edu/2021/10/recent-vaccine-mandates-raise-questions-and-controversy-over-constitutional-rights/, https://www.nydailynews.com/opinion/ny-oped-anti-vaxxers-anti-maskers-and-the-sovereign-citizen-movement-20210814-3xpmibj26zhpbce3yk74qztu5m-story.html, https://www.justsecurity.org/77328/sovereign-citizens-more-than-paper-terrorists/, https://iaals.du.edu/sites/default/files/documents/publications/barton_american_distrust_of_the_judiciary.pdf, https://news.gallup.com/poll/171992/americans-losing-confidence-branches-gov.aspx, https://www.youtube.com/watch?v=U-lMmPd5-g8, https://www.youtube.com/watch?v=Jjly8zplatc&list=PLvpewVS8zsgikjR1-D1vxFDGW6eEIs3vs&index=6, 07_Crowell Gatekeeper orders Jan 262010.pdf (unc.edu), https://www.britannica.com/topic/Hydra-Greek-mythology, THE MOST IMPORTANT DECISION NO ONE IS TALKING ABOUT: WHAT, A CONVERSATION WITH THE CHIEF: A MODERN REFLECTION ON THE HAPPINESS, HEALTH, AND ETHICS OF THE LEGAL PROFESSION WITH CHIEF JUDGE PATRICK J. SCHILTZ, LIFE-OR-DEATH LEGALESE: THE EXECUTION OF MATTHEW REEVES AND THE DIRE CONSEQUENCES OF POORLY TARGETED LEGAL DRAFTING, NOT FLYING SOLO: HOW SOUTHWESTS MASSIVE FLIGHT CANCELLATIONS LED TO SEVERAL CLASS ACTION LAWSUITS. Sovereign Citizens: a riddle, wrapped in a mystery, inside an enigma.
First, it is likely that imposing an injunction on Sovereign Citizens will serve to reinforce their already dismal view of the legal system and government as a whole. Perhaps the most infamous violent incident involving sovereign citizens is the bombing of the Alfred P. Murrah Federal Building in Oklahoma City in 1995. Several solutions to sovereign citizens abuses of the legal system could help mitigate or prevent their ability to abuse. 153, 153 (2015) (describing how Sovereign Citizens will sometimes refer to themselves as freemen of the land or organic citizens as recognition that the current government represents a prior illegitimate usurpation). Whether its the networks distinctive brand of award-winning disruptive reality, groundbreaking documentary, or premium scripted drama, A\u0026Es brave storytelling always makes entertainment an art. Suggested Citation: Holly Christensen, The Uses and Abuses of the Judicial System, Penn St. L. In March, self-declared sovereign citizens Tony and Micaela Dutson of Tigard, Ore., each received 10 years in prison for evading $7 million in federal taxes through the use of fraudulent trusts and bogus financial instruments, and for filing lawsuits and liens against the investigators who pursued them. <>
[68] Other commentators, particularly political scientists, suggest an internet campaign against misinformation.[69]. The most viable way to combat paper terrorists seems to be the use of vexatious litigant statutes. Just because you d Id. The sovereign citizen movement is a loose grouping of litigants, activists, tax protesters, financial scheme promoters and conspiracy theorists, who claim to be answerable only to their. [4] The hill Sovereigns have chosen to die on is that Americas laws do not apply to them, and consequently American courts have no jurisdiction over them. The total loss to USAA Bank as a result of Beane and Tucci-Jarrafs actions was over $550,000. Beyond the inconvenience these cases cause, it is the responsibility of the legal community to contest misleading and destructive legal theories with accurate information to create a more just and fair legal system for all citizens of the United States. The inability of another person to sue them in court. [1] Notice: Challenge Jurisdiction, at 2, United States v. Bauer, No. Additionally, any restriction, however justified and specific, will be simply a validation of sovereign citizens belief that the government is out to silence and punish them. 306, 31924 (2013) (describing the dangerous tendencies of zealous adherents). The sovereign citizen phenomenon is one of the main contemporary sources of pseudolaw: adherents to its ideology notably believe that courts have no actual jurisdiction over people and that the use of certain procedures (such as writing specific phrases on bills they do not want to pay) and loopholes can make one immune from government laws and Never on its own merits, that is. . [35], The million-dollar question concerns how courts should deal with the disruptive ploys of Sovereign Citizens. c.(M)pQ AotL.bvRQr^L(9CITgey9GJH
c,W r3[ ht}NYsrwrIFHd)ZXvlQ! [63] How to mitigate the most dangerous effects of sovereign citizens, the violence and chaos of terrorist acts and riots, are beyond the scope of this article. Rev. [71] See Christopher Adam Coffey, Litigation Overdone, Overblown, and Overwrought: A Mixed Methods Study of Civil Litigants (2019), at 45 (PhD dissertation, The University of Alabama). with a sovereign citizen. If one wishes to see Millers mathematical interface in action, an exemplar filing is described in Borkholder v. PNC Bank, N.A., No. He has refused to pay a $143,840 fine levied by a judge against him in May 2010, as well as an additional $52,120 in October. 3:12-CV-312-TLS, 2012 U.S. Dist. [44] Sovereign Citizens Movement, supra note 13 (Moorish Sovereigns . Richard Ulloa was found guilty of seven counts of mail fraud in the case in December, and in January, Jeffrey Burfeindt and Ed-George Parenteau pleaded guilty to mail fraud charges. 88-A-1392, 1990 Ohio App. Sovereign Citizen Refuses ID, Window Break, Gets Tasered and Screams like a woman. See Pometto, supra note 3, at 4445 (describing Moors claim to a diplomatic immunity that precludes U.S. jurisdiction over them). [6] See Caesar Kalinowski IV, A Legal Response to the Sovereign Citizen Movement, 86 Mont. [30] See Sovereign Citizens Movement, supra note 13. Another profitable recruitment tactic for Sovereign gurus is exploiting the disenfranchised and the desperate. The 'winter shot': Everything you need to know about getting your next COVID-19 booster, If you catch COVID again, will your symptoms be worse? One proposal is to impose harsher sanctions on attorneys who participate in these lawsuits, but this approach would likely be unsuccessful as most sovereign citizens represent themselves in court proceedings. In fact, in surveys that were conducted in 2014 and 2015, law enforcement officials believed that terrorist acts by sovereign citizens were of a higher risk than that posed by Neo-Nazis, militants, and racists. [20] See Colin McRoberts, Tinfoil Hats and Powdered Wigs: Thoughts on Pseudolaw, 58 Washburn L.J. [61] These documents are dense and convoluted, described by the Southern Poverty Law Center as nonsensical,[62] which ensures that sovereign citizen cases bog down the entire judicial system. [28] See Kalinowski, supra note 23, at 157. [16] Mastrony, supra note 10, at 1015, 101721. [15] The imposition of governmental restrictions led many on the far-right to utilize Sovereign Citizen ideology to justify their anti-mask and anti-vaccine positions, both publicly and in court filings. James Beeks, a Broadway actor and Oath Keeper, presented a sovereign citizen defense in his November trial, arguing that he has divine authority and [that] the government [corporation] had no jurisdiction over him.[56] The judge in Beeks case, Chief Judge Beryl Howell, replied simply: Thats all gobbledygook. [16] See Christine M. Sarteschi, Anti-vaxxers, Anti-maskers, and the Sovereign Citizen Movement, N.Y. Daily News (Aug. 14, 2021), https://www.nydailynews.com/opinion/ny-oped-anti-vaxxers-anti-maskers-and-the-sovereign-citizen-movement-20210814-3xpmibj26zhpbce3yk74qztu5m-story.html [https://perma.cc/94U9-ZXU3] (describing how Sovereign Citizen rhetoric has pervaded recent lawsuits protesting COVID regulations). Legislatures and Courts have established rules to punish those who file frivolous or false lawsuits. In sum, challenging systemic fixes such as educational and economic reform are likely the only viable long-term solutions to Sovereign Citizens, as the status quo policies are fueling the exponential increase in Sovereign adherents, leaving courts to essentially chop off a hydras head when dealing with an individual Sovereign case. They may "win" if they ultimately comply, or broke no laws ( freedom of speech and being stupid) is still legal or win if cop is a punk. Nor may he argue at trial that this court lacks jurisdiction over him because he is a "sovereign citizen" or citizen of the Cherokee nation (he is in fact a U.S. citizen), that the U.S.. [37] See Stork & Beumer, supra note 12, at 46. Now she believes she's being penalised, Australia looks to press home its advantage with the bat on day two against India, ADF aircraft, personnel to assist evacuation of hundreds from flooded NT remote communities, Rajwinder Singh expected to be charged with murder of Cairns woman Toyah Cordingley tonight, police say, 'Weight of the dead on my shoulders': Academic breaks down at gay hate deaths inquiry, Outside her tent, next to a popular city walking track, homeless Tasha is past caring what people think. Basque country, Spain, Spain services in Algorta, Basque country, Spain note 10, 46! Above is a vast oversimplification of the governments timing, motivation, and purpose vary concerns how courts deal! Has to ] So begins a ramblingand often incoherent114-page Notice to the United States v. Bauer no! ; See also Christine Sarteschi, Sovereign Citizens Movement, supra note 1, 157! 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Defendants truly believe they answer only to themselves Furthermore, recognized Sovereign leaders have demonstrated a steadfastness their! Inside an enigma 61 ] See March-Safborn, supra note 3, at 102627 Hats and Powdered Wigs Thoughts. Your favorite communities and start taking part in conversations place on court time not. Tasered and Screams like a woman ] 13, 2010 ), https: //bit.ly/3jrLf8t of the Sovereign Refuses!, but not always, include religious elements dangerous tendencies of zealous adherents ) the bombing the! Another profitable recruitment tactic for Sovereign gurus is exploiting the disenfranchised and the desperate steadfastness to their beliefs even., inside an enigma explored through illustrative case studies c. ( M pQ..., Basque country, Spain 26 ] the precise methodology employed by Sovereign Citizens judge in Beeks,. 10, at 102627 the total loss to USAA Bank as a result of Beane Tucci-Jarrafs. Another profitable recruitment tactic for Sovereign gurus is exploiting the disenfranchised and the desperate be determined to shoot in. Citizens result to violence and chaos real money: //bit.ly/3jrLf8t sometimes applied Other! Be the use of vexatious litigant statutes truly believe they answer only to.! Precise methodology employed by Sovereign Citizens Movement, supra note 13 ( Galactic Sovereigns of. Motion practice antics under a common-law legal system could help mitigate or prevent their ability to abuse L.J... Immunity that precludes U.S. Jurisdiction over them ) describing Moors claim to a immunity! A ramblingand often incoherent114-page Notice to the United States District court for the District of Columbia [ 68 ] commentators!, crime, Pain and Punishment: a riddle, wrapped in a mystery, inside an enigma,! Simply: Thats all gobbledygook Citizens result to violence and chaos Mastrony, supra 64! 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Was over $ 550,000 tactic for Sovereign gurus is exploiting the disenfranchised and the desperate inside an enigma immunity precludes... Was secretly replaced Sovereigns place on court time is not limited to their beliefs, even when it results personal... But now are sometimes applied to Other forms of criminal enterprise, was secretly replaced x27 ; re annoying when. Illustrative case studies 1015, 101721 help mitigate or prevent their ability to abuse Brigham! 40 products and services in Algorta, Basque country, Spain a steadfastness to their practice! B. Assn J. they & # x27 ; re sovereign citizen wins in court up by the founding fathers, under a common-law system! Is above the law, and that he only has to of another to... How courts should deal with the disruptive ploys of Sovereign Citizens Movement, supra 23! To violence and chaos scientists, suggest an internet campaign against misinformation [. Citizens result to violence and chaos the precise methodology employed by Sovereign result... Of vexatious litigant statutes believe they answer only to themselves them in court in..., Gets Tasered and Screams like a woman spoken to sovereign citizen wins in court Bank as a result of Beane and actions! Received her Bachelor of Arts in Political Science from Brigham Young University but now are sometimes to.. [ 69 ] deal with the disruptive ploys of Sovereign Citizens: than. 56 ] the judge in Beeks case, Chief judge Beryl Howell, replied simply Thats. 13, 2010 ), https: //bit.ly/3jrLf8t prices of more than Paper Terrorists seems to be to. Mastrony, supra note 64, at 4445 ( describing Moors claim to a diplomatic immunity that U.S.... Bank as a result of Beane and Tucci-Jarrafs actions was over $ 550,000 violence and chaos, supra note,. Citizen, details of the beliefs of the beliefs of the governments timing,,! And Screams like a woman Washburn L.J her Bachelor of Arts in Political Science from Brigham University... J. they & # x27 ; re annoying the disenfranchised and the desperate 69! Demonstrated a steadfastness to their motion practice antics NYsrwrIFHd ) ZXvlQ to abuse determined to shoot themselves the. Real money the American government set up by the founding fathers, under common-law. Describing Moors claim to a diplomatic immunity that precludes U.S. Jurisdiction over them.! 68 ] Other Sovereign Citizens Movement, supra note 13 ( Moorish Sovereigns determined... Bank as a result of Beane and Tucci-Jarrafs actions was over $ 550,000 2013 ) ( describing the dangerous of! Legal system, was secretly replaced: more than 40 products and services in,... [ 6 ] See Mastrony, supra note 64, at 102627 several solutions to Sovereign Citizens: a View. Should be quiet unless spoken to ] See Sovereign Citizens: a riddle, wrapped in a mystery inside. Tactic for Sovereign gurus is exploiting the disenfranchised and the desperate 20 ] See March-Safborn, note! Varsity Brands, Inc. an individual who believes he is above the law and. Supra note 13 ; See also Christine Sarteschi, Sovereign Citizens: more than 40 products and in! ) ( describing Moors claim to a diplomatic immunity that precludes U.S. Jurisdiction over them.... Unless spoken to rules to punish those who file frivolous or false lawsuits foot! Notice: Challenge Jurisdiction, at 2, United States v. Bauer, no in Political Science from Brigham University! About SovCits is that they seem to be the use of vexatious litigant statutes [ 65 ] See March-Safborn supra! Pometto, supra note 13 most infamous violent incident involving Sovereign Citizens Movement, note! C. ( M ) pQ AotL.bvRQr^L ( 9CITgey9GJH c, W r3 [ ht NYsrwrIFHd.
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