Sovereign citizen movement
The sovereign citizen movement is a loose grouping of American litigants, commentators, tax protesters and financial-scheme promoters. Self-described sovereign citizens take the position that they are answerable only to their particular interpretation of the common law and are not subject to any statutes or proceedings at the federal, state or municipal levels or that they do not recognize U.S. currency and 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 "federal citizens" who, they say, have unknowingly forfeited their rights by accepting some aspect of federal law.
Many members of the sovereign citizen movement believe that the U.S. government is illegitimate. JJ MacNab, who writes for Forbes about anti-government extremism, describes 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 Federal Bureau of Investigation (FBI) classifies some sovereign citizens ("sovereign citizen extremists") as a domestic terrorist movement. 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."
A 2014 report by the National Consortium for the Study of Terrorism and Responses to Terrorism stated that a survey of law-enforcement officials and agencies across the United States concluded that the movement was the single greatest threat to their communities, ranking above Islamic terrorists and jihadists.
Richard McDonald has established State Citizen Service Centers around the United States. Writing in American Scientific Affiliation, Dennis L. Feucht describes McDonald's theory, which claims 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 Feucitizen 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 land owner, 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.
Critics of sovereign citizen theory assert that sovereign citizens fail to sufficiently examine the context of the case laws from which 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.
The concept of a sovereign citizen originated 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.
Some of those in the movement consider the term "sovereign citizen" an oxymoron, preferring to view themselves as sovereign individuals "seeking the Truth".
Legal status of theories
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 IRS 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 Serv. (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 $3,000 penalty on Stoecklin for filing a frivolous appeal).
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 Serv. (Heather Rowe's argument—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)..."—was rejected by the Court and was 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 Internal Revenue Service 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 Internal Revenue Service 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, in a case in which an individual named 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 has 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.
- 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.)
- 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.)
- 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......
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.
Filing of false lien notices
The New York Times reports that 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 person's credit rating. 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, a tort.
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 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 tabs. 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 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 forcibly arrest the mayor of Kirkland, Washington. Myrland was released from prison on January 29, 2014.
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 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. Davis is inmate # 43741-048 at the La Tuna Federal Correctional Institution at Anthony, Texas near El Paso, and is scheduled for release on April 24, 2017.
In September 2011, Edward and Elaine Brown, serving long federal prison sentences for various crimes, were identified by the Federal Bureau of Investigation as being members of the sovereign citizen movement.
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.
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 pled guilty to tax fraud. He admitted to having filed about 50 falsified tax returns. Federal prosecutors contended that Garrison's actions cost the Internal Revenue Service 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, Francis August 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. Chi had been projected to serve over 20 years in federal prison. 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. No trial date has been set.
On July 19, 2012, Martin Jonassen, who had described himself as a sovereign citizen, was found guilty by a jury in a 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 Alaska couple who were described as "followers of Schaeffer Cox", pled 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 Internal Revenue Service 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.
On September 10, 2012, David B. Graham of Gwinnett County, Georgia pled guilty to 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. Code (relating to fictitious documents), one count of filing false Form 1096 reports with the Internal Revenue Service, 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 United States Penitentiary, Marion, Illinois, 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 Federal Bureau of Investigation also alleged that Ballard had a back up 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 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 Richard 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 Federal Bureau of Investigation 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 the Brooklyn Metropolitan Detention Center at Brooklyn, New York, and is scheduled for release on January 13, 2020.
In May 2013, the Criminal Investigation division of the Internal Revenue Service issued its Annual Business Report for 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 Federal Bureau of Investigation 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 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.
On January 9, 2014, sixty-seven 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 Internal Revenue Service.
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 Internal Revenue Service 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 US 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 US 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.
In the media
"Public Enemy", an episode of the crime drama television program The Glades first broadcast July 15, 2012, depicted the sovereign citizen movement as a mixture of fraudulent promoters and sincere believers, whose proclivity for violence (Terry Nichols' links to the movement are explicitly mentioned) and for harassment by means of fraudulent legal motions intimidate professional law enforcement officers and civil service functionaries. It represented the movement as arguing that by changing one's name on birth certificates, driver's licenses and the like, one can reclaim one's status as a sovereign.
- Embassy of Heaven
- Freemen on the land
- Guardians of the Free Republics
- Moorish Science Temple of America
- Social contract
- Tax protester
- Yerak, Becky; Sachdev, Ameet (June 11, 2011). "Giordano's strange journey in bankruptcy". Chicago Tribune.
- Also, see generally Kevin Johnson, "Anti-government 'Sovereign Movement' on the rise in U.S.", March 30, 2012, USA Today, at .
- "'Sovereign Citizen' Suing State Arrested Over Traffic Stop", April 6, 2012, WRTV Indianapolis, at .
- The Sovereign Citizen Movement. The Militia Watchdog Archives. Anti-Defamation League.
- Carey, Kevin (July 2008). "Too Weird for The Wire". Washington Monthly. Retrieved July 19, 2008.
- "Context Matters: the Cliven Bundy Standoff". Forbes.com. Retrieved 2 May 2014.
- MacNab, JJ. "Context Matters: The Cliven Bundy Standoff -- Part 3". Forbes. Retrieved 6 May 2014.
- "Sovereign Citizens A Growing Domestic Threat to Law Enforcement". Domestic Terrorism. Federal Bureau of Investigation. September 11, 2011. Retrieved July 19, 2012.
- MacNab, J.J. "'Sovereign' Citizen Kane". Intelligence Report. Issue 139. Southern Poverty Law Center. Fall 2010.
- Parker, Jameson. "Study: Greatest Terrorism Threat In America Not Al Qaeda, It’s Right-Wing Sovereign Citizens" addicting info.org August 3, 2014
- Jessica Rivinius, "Sovereign citizen movement perceived as top terrorist threat," July 30, 2014, National Consortium for the Study of Terrorism and Responses to Terrorism, at .
- David Carter, Steve Chermak, Jeremy Carter & Jack Drew, "Understanding Law Enforcement Intelligence Processes: Report to the Office of University Programs, Science and Technology Directorate, U.S. Department of Homeland Security," July 2014, National Consortium for the Study of Terrorism and Responses to Terrorism (College Park, Maryland), at 
- Feucht, Dennis (June 1997). "Essay Review of AMERICAN MILITIAS: Rebellion, Racism & Religion". Perspectives on Science and Christian Faith. American Scientific Affiliation. pp. 116–118. Retrieved September 4, 2014.
- Hall, Kermit; Clark, David Scott (2002). The Oxford Companion to American Law.
- Fleishman, David (Spring 2004). "Paper Terrorism: The Impact of the 'Sovereign Citizen' on Local Government". The Public Law Journal 27 (2).
- Smith, William C. (November 1996). "The Law According to Barefoot Bob". ABA Journal.
- J.J. MacNab, (February 13, 2012)"What is a Sovereign Citizen?". Forbes.
- 37 T.C.M. (CCH) 189, T.C. Memo 1978-32 (1978), at .
- 37 T.C.M. (CCH) 1539, T.C. Memo 1978-372 (1978), at .
- 701 F.2d 749 (8th Cir. 1983) (per curiam), at .
- 596 F. Supp. 141 (N.D. Ind. 1984), at .
- 865 F.2d 1221 (11th Cir. 1989), at .
- Docket # 18494-95, 71 T.C.M. (CCH) 2210, T.C. Memo 1996-82, United States Tax Court (February 26, 1996), at .
- 409 F.3d 354 (D.C. Cir. 2005), at .
- Case no. 06-27-P-S, U.S. District Court for the District of Maine (May 9, 2006), at .
- Case no. CV-07-209-E-BLW, U.S. District Court for the District of Idaho (June 29, 2007).
- Docket # 16905-05L, T.C. Memo 2009-88, United States Tax Court (April 28, 2009), at .
- Case no. 10-MC-6-SLC, U.S. District Court for the Western District of Wisconsin (June 4, 2010), at .
- 912 F.Supp. 224 (N.D. Tex. 1996), at .
- "The Truth about Frivolous Tax Arguments". Internal Revenue Service. January 1, 2011.
- United States v. Schneider, 910 F.2d 1569 (7th Cir. 1990), at .
- Order, docket entry 102, Feb. 12, 2013, United States v. Kenneth Wayne Leaming, case no. 12-cr-5039-RBL, U.S. District Court for the Western District of Washington.
- Jury verdicts, Feb. 28, 2013 and March 1, 2013, United States v. Kenneth Wayne Leaming, case no. 12-cr-5039-RBL, U.S. District Court for the Western District of Washington.
- News release, May 24, 2013, Office of the United States Attorney for the Western District of Washington, at . Leaming is incarcerated at the United States Penitentiary at Marion, Illinois, and is scheduled for release on February 13, 2019. See Federal Bureau of Prisons record, Kenneth Wayne Leaming, inmate # 34928-086, U.S. Dep't of Justice.
- Erica Goode (August 23, 2013). "In Paper War, Flood of Liens Is the Weapon". The New York Times. Retrieved August 24, 2013.
- Pepke, David Ray (1998) Heretics in the Temple
- Dan Harris, Deadly Arkansas Shooting By 'Sovereigns' Jerry and Joe Kane Who Shun U.S. Law (July 1, 2010), ABC News.
- Michael Braga, Economy Boosts Sovereign-Citizen Movement (July 30, 2011), Sarasota Herald-Tribune.
- "Kirkland Man Sentenced To 40 Months In Prison For Threatening Public Officials" (Press release). Office of the U.S. Attorney for the Western District of Washington. December 2, 2011.
- "Man gets 3 years for threatening Kirkland mayor". The Bellingham Herald. December 2, 2011.
- Phelps, Matt (October 4, 2010). "Reporter informs Redmond man of charges in alleged threats against Kirkland Mayor, Assistant City Attorney". Redmond Reporter.
- "RCW 9A.16.020: Use of force—When lawful." Revised Code of Washington. Washington State Legislature. Retrieved December 16, 2011
- David Russell Myrland, inmate # 40941-086, Federal Bureau of Prisons, U.S. Dep't of Justice.
- John L. Smith. Conviction chips away at Sovereign Citizen guru's facade (March 27, 2011). Las Vegas Review-Journal.
- Jeff German, "Judge sentences anti-government leader to prison," October 27, 2011, Las Vegas Review-Journal, at .
- See generally United States v. Samuel Davis, case no. 2:09-cr-00078-JCM-RJJ, U.S. District Court for the District of Nevada.
- Jeff German, July 24, 2012, "Leader in anti-government movement convicted of money laundering," Las Vegas Review-Journal, at .
- Jeff German, "Sovereign citizens leader, fugitive from Las Vegas, arrested in North Dakota," Aug. 14, 2012, Las Vegas Review-Journal, at .
- Federal Bureau of Prisons, U.S. Dep't of Justice, at .
- "Sovereign Citizens: A Growing Threat to Law Enforcement," Law Enforcement Bulletin (Sept. 2011), Counterterrorism Analysis Section, Federal Bureau of Investigation, U.S. Department of Justice, at .
- News Release, Nov. 4, 2011, "Self-Proclaimed 'Governor' of Alabama and Wife Convicted of Tax Fraud," Office of Public Affairs, U.S. Department of Justice, at .
- News Release, May 29, 2012,"Self-proclaimed “Governor” of Alabama Sentenced to Ten Years in Federal Prison for Tax Fraud," Office of Public Affairs, U.S. Department of Justice, at .
- Brian Bennett, "'Sovereign citizen' movement now on FBI's radar," Feb. 23, 2012, Los Angeles Times, at .
- "Anti-government leader found guilty in Vegas case," July 24, 2012, Associated Press, as published by the San Francisco Chronicle, at .
- William D'Urso, "‘Sovereign citizen’ gets 8 years in money laundering case," March 20, 2013, Las Vegas Sun, at .
- Shawn Rice, inmate # 89135-008, Federal Bureau of Prisons, U.S. Dep't of Justice.
- Levi Pulkkinen, "Washington accountant sentenced to prison for 'crusade’ against IRS", Feb. 1, 2012, at .
- Record, inmate # 13961-086, Federal Bureau of Prisons, U.S. Dep't of Justice.
- Ben Anderson, "Alaska militia trial: Cox, Vernon found guilty of conspiracy to murder", June 18, 2012, Alaska Dispatch, at .
- Richard Mauer & Lisa Demer, "Jury convicts militiamen on most charges", June 18, 2012, Anchorage Daily News, at .
- Jill Burke, "Militia leader Schaeffer Cox gets a nearly 26 year prison sentence," Jan. 8, 2013, Alaska Dispatch, at .
- J.J. MacNab, July 3, 2012, "Sovereign Extremist Injured in Texas Bomb Explosion", Forbes, at .
- "Texas man reaches plea deal in pipeline blast case," Associated Press, June 3, 2013, at .
- Oral order, Feb. 26, 2014, United States v. Chi, case no. 4:12-cr-00155-RAS-DDB, U.S. District Court for the Eastern District of Texas.
- The charges were kidnapping and obstruction of justice Third Superseding Indictment, docket entry 215, May 16, 2012, United States v. Jonassen, case no. 2:11-cr-00163-JTM-PRC, U.S. District Court for the Northern District of Indiana (Hammond Div.).
- Lu Ann Franklin, "Jonassen guilty of kidnapping daughter," July 19, 2012, Times Media Company, at .
- Sarah Tompkins, "Officials: Man accused of kidnapping in Portage a part of extremist group," Sept. 27, 2011, Times Media Company, at .
- Marisa Kwiatkowski, Feb. 20, 2013, "Kansas man sentenced to 40 years in kidnapping case," Times Media Company (Munster, Indiana), at .
- Martin J. Jonassen, inmate # 11817-027, Federal Bureau of Prisons, U.S. Dep't of Justice.
- Claire Galofaro, Aug. 17, 2012, "'Sovereign citizens' group rejects most government authority," New Orleans Times Picayune, at .
- Rosen, Yereth. "Alaska couple admits to plot to kill federal judge and others" Reuters August 28, 2012
- "Lonnie, Karen Vernon Sentenced In Militia Trials," Jan. 7, 2013, Associated Press, at .
- Rebecca Palsha, Jan. 7, 2013, "Lonnie Vernon Gets Over 25 Years for Murder Plot," KTUU-TV News, Anchorage, Alaska, at .
- Marcus K. Garner, "Gwinnett man pleads guilty to stealing foreclosed home," Sept. 10, 2012, The Atlanta Journal-Constitution, at .
- Kevin Johnson, "Feds charge 'president' of sovereign citizen group," Sept. 18, 2012, USA Today, at .
- Indictment, docket entry 1, Sept. 12, 2012, United States v. Turner, case no. 1:12-cr-00169-MHT-WC, U.S. District Court for the Middle District of Alabama (Dothan Div.).
- "Man in 'sovereign citizen' movement indicted," Associated Press, Sept. 18, 2012, as published by CBS News, at .
- Carol Cratty, "Federal prosecutors bring tax charges against leader of anti-government group," Sept. 18, 2012, CNN, at .
- "The Sovereigns: Leaders of the Movement," Intelligence Report, Fall 2010, Issue # 139, Southern Poverty Law Center, at .
- News release, U.S. Dep't of Justice, July 31, 2013, at .
- Ryan Lenz, "Sovereign 'President' Sentenced to 18 Years in Federal Prison for Tax Crimes," July 31, 2013, Southern Poverty Law Center, at .
- See generally James Timothy Turner, inmate # 14154-002, Federal Bureau of Prisons, U.S. Dep't of Justice, at .
- Kevin Krause, "Man facing trial on federal tax charges in Fort Worth accused of trying to arrange hit on judge," Oct. 1, 2012, The Dallas Morning News, at .
- Alice Wolke, "Elderly tax protester solicited judge's murder, DA says," Oct. 1, 2012, KDFW-TV/Fox News, at .
- Scott Gordon, "FBI: Inmate Tried to Kill Federal Judge," Oct. 1, 2012, NBC/Universal, at .
- Domingo Ramirez Jr., "Fort Worth man sentenced to 20 years for trying to hire hit man to kill judge," March 17, 2014, Fort Worth Star-Telegram, at .
- United States v. Ballard, case no. 4:13-cr-00067, U.S. District Court for the Northern District of Texas.
- Order Granting Motion to Dismiss Indictment, April 10, 2014, entry 68, United States v. Ballard, case no. 4:11-cr-00038, U.S. District Court for the Northern District of Texas.
- Phillip Monroe Ballard, inmate # 16229-077, Federal Bureau of Prisons, U.S. Dep't of Justice.
- WECT Staff, "911 operator talks about $300,000 request in exchange to pull over," Dec. 11, 2012, © 2012 WorldNow and WCSC, at .
- Dec. 11, 2012, "911 operator talks about $300,000 request in exchange to pull over," WAFF-TV News, Huntsville, Alabama, at .
- Nadine Maeser, Feb. 1, 2013, "Woman indicted by grand jury, claims herself as a "sovereign citizen", WECT-TV News, Wilmington, North Carolina, at .
- Roger Dupuis, "Who is Glenn Richard Unger?", Jan. 20, 2013, Daily Courier-Observer (Massena & Potsdam, New York), at .
- Indictment, Dec. 19, 2012, United States v. Unger, case no. 1:12-cr-00579-TJM, U.S. District Court for the Northern District of New York.
- Robert Gavin, May 23, 2013, "Mental test slated for activist leader," Albany Times-Union, at .
- Docket entry, Aug. 7, 2013, United States v. Unger, case no. 1:12-cr-00579-TJM, U.S. District Court for the Northern District of New York.
- Robert Gavin, "Jury: Sovereign citizen 'elder' guilty of tax crimes," Oct. 21, 2013, Albany Times-Union (Albany, New York), at .
- Robert Gavin, April 21, 2014, "'Sovereign citizen' quotes Bible, touts Maury Povich at sentencing," Albany Times-Union, at .
- Glenn R. Unger, inmate # 20191-052, Federal Bureau of Prisons, U.S. Dep't of Justice.
- Annual Business Report, Fiscal Year 2012, National Operations, pp. 24-25, Criminal Investigation, Internal Revenue Service, U.S. Dep't of the Treasury (May 10, 2013).
- News Release, "Sovereign Citizen Sentenced to More Than Eight Years in Prison for Tax Fraud Scheme," June 14, 2013, Federal Bureau of Investigation, U.S. Department of Justice, at .
- Nevada pair plotted to torture and kill police
- Arrest of 2 in Sovereign Citizen Plot to Kidnap Police Officers FOX News August 23, 2013
- "Woman Takes Plea Deal in Sovereign Citizen Case," Dec. 12, 2013, KLAS-TV Channel 8 News, Las Vegas, Nevada, at 
- Francis McCabe, Feb. 3, 2014, "Defendant pleads guilty to conspiring to kidnap cop," Las Vegas Review-Journal, at .
- Francis McCabe, April 7, 2014, "Man sentenced to probation in Las Vegas for domestic terrorist plot," Las Vegas Review-Journal, at .
- "Man 'seizes' eleven abandoned family homes in Ohio whilst the owners are out of town". Mail Online. 30 November 2013. Retrieved 9 February 2014.
- Gettys, Travis (6 December 2013). "Grand jury indicts Ohio ‘sovereign citizen’ accused of trying to steal 11 homes". The Raw Story. Retrieved 9 February 2014.
- "'Sovereign citizen' tax preparer gets 6 years in prison," Jan. 9, 2014, Chicago Tribune, at .
- Kevin Murphy, "Glavin sentenced to jail," Feb. 13, 2014, Juneau County Star-Times, at .
- John Glavin, inmate # 08025-090, Federal Bureau of Prisons, U.S. Dep't of Justice.
- Suckling, Kieran. "A rancher's armed battle against the US government is standard libertarian fare". The Guardian. Retrieved 28 April 2014.
- Daniel Hernandez, and Joseph Langdon (13 April 2014). "Federal rangers face off against armed protesters in Nevada 'range war'". The Guardian. Retrieved 19 April 2014.
- Murphy, Vanessa (19 April 2014). "The Bundy militia, who are they?". KLAS TV Las Vegas News. Retrieved 19 April 2014.
- Flynn, Michael (16 April 2014). "Amazing footage captures Bundy's militia standoff with BLM & Police". The Independent, News, St. George Utah. Retrieved 19 April 2014.
- Macneal, Caitlin. "Harry Reid Calls Bundy Supporters 'Domestic Terrorists'". Talking Points Memo, TPM Media LLC. Retrieved 19 April 2014.
- Z, Jimmy. "Bundy Militia Protester Advocates Women As Human Shields". The 405 Media. Retrieved 19 April 2014.
- Allen, Jonathan (17 April 2014). "Bundy Ranch Standoff Emboldens Militia Groups". Retrieved 19 April 2014.
- Komenda, Ed (10 April 2014). "Militiamen make their presence felt in protest of BLM’s livestock grab". Las Vegas Sun. Retrieved 19 April 2014.
- Allen, Jonathan (17 April 2014). "After Nevada ranch stand-off, emboldened militias ask: where next?". Retrieved 19 April 2014.
- Political cause growing in Bundy's dispute with BLM "Political cause growing in Bundy's dispute with BLM". KLAS-TV Las Vegas. Retrieved 6 May 2014.
- "Three Men Convicted of Defrauding Customers Through Bogus Debt Elimination Scheme". Press release. FBI. Retrieved 5 April 2014.
- "http://www.ajc.com/news/news/police-activity-around-forsyth-courthouse/ngFsZ/". The Atlanta Journal-Constitution. June 6, 2014.
- David Neiwert, "'Sovereign Citizen' Is Suspected in Georgia Courthouse Shooting," June 6, 2014, Southern Poverty Law Center, at .
- See generally Dennis Marx v. Forsyth County Sheriff's Office et al., case no. 2:13-cv-00175-RWS, U.S. District Court for the Northern District of Georgia (Gainesville Div.).
- Greg Botelho, Eliott C. McLaughlin & Jason Hanna, "Authorities: Georgia courthouse attacker prepared to inflict mayhem," June 6, 2014, CNN, at .
- Annie Sweeney & Jason Meisner, "Chicago woman's trial could get wild," Aug. 2, 2013, Chicago Tribune.
- Annie Sweeney & Jason Meisner, "Chicago woman's trial could get wild," Aug. 2, 2013, Chicago Tribune.
- Jason Meisner, " 'Sovereign citizen' given 7 years in prison for bogus liens," Oct. 14, 2014, Chicago Tribune, at .
- The Glades Episode Guide
- Sovereign Citizen Movement Southern Poverty Law Center (SPLC)
- SPLC's Video Informing Law Enforcement on the Dangers of "Sovereign Citizens"
- FBI page on the Sovereign Citizen movement
- Sovereign Citizen Movement - Anti-Defamation League
- 60 Minutes documentary about Sovereign citizens
- "Common Law and Uncommon Courts: An Overview of the Common Law Court Movement", Mark Pitcavage, The Militia Watchdog Archives, Anti-Defamation League, July 25, 1997.