3:21-cr-00108
M.D. Tenn.Nov 16, 2022Background:
- Defendant David Haley is indicted in the Middle District of Tennessee on four counts of filing false tax returns under 26 U.S.C. § 7206.
- Haley submitted documents construed as a motion to dismiss for lack of jurisdiction, arguing he is not a U.S. citizen, has renounced citizenship, formed a Tennessee entity, and is a foreign sovereign immune from U.S. law.
- The Government opposed the motion; Haley did not file a reply after being granted time to do so.
- The Court observed Haley had previously appeared multiple times in the case without contesting jurisdiction and raised the jurisdictional challenge for the first time on the morning of trial.
- The Court found federal subject-matter jurisdiction under 18 U.S.C. § 3231 and personal jurisdiction over Haley; it rejected his contract and sovereign-citizen arguments as frivolous and legally unsupported.
- The Court denied Haley’s motion to dismiss the indictment.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject-matter jurisdiction over federal criminal prosecutions | Gov't: federal courts have original jurisdiction over offenses against federal law | Haley: not subject to U.S. laws because he renounced U.S. citizenship and is a foreign sovereign | Court: federal jurisdiction exists under 18 U.S.C. § 3231; Haley's claim is meritless |
| Personal jurisdiction / appearance | Gov't: Haley has appeared in court multiple times and is before the Court | Haley: attempted special appearance to contest jurisdiction | Court: personal jurisdiction proper; special-appearance claim rejected |
| Contract/sovereign-citizen defenses | Gov't: state contract law and related civil arguments are inapplicable in federal criminal case | Haley: argues no valid contract with U.S.; claims state-entity status and immunity | Court: arguments are frivolous and without legal support; denied |
Key Cases Cited
- United States v. Titterington, 374 F.3d 453 (6th Cir. 2004) (recognizes federal district courts’ jurisdiction over federal offenses)
- United States v. Pryor, 842 F.3d 441 (6th Cir. 2016) (rejects special-appearance/personal-jurisdiction challenge)
- United States v. Mundt, 29 F.3d 233 (6th Cir. 1994) (describes similar jurisdictional objections as patently frivolous)
- United States v. Coleman, 871 F.3d 470 (6th Cir. 2017) (collects cases rejecting sovereign-citizen and related claims)
- United States v. Amir, [citation="644 F. App'x 398"] (6th Cir. 2016) (declines to credit defendant’s claim of alternative citizenship to avoid federal jurisdiction)