United States v. Raymond McLaughlin, 949 F.3d 780

Defendant Raymond McLaughlin submitted fabricated documents to the IRS in 2014 purporting a $300,000+ payment to a Connecticut state judge; charged under 18 U.S.C. § 1001 for making false statements.
McLaughlin was tried in the U.S. District Court for the District of Connecticut and convicted by a jury.
Pre-trial and on appeal McLaughlin, proceeding pro se, repeatedly argued the District Court lacked personal jurisdiction over him, invoking sovereign-citizen–style claims that federal courts lack authority.
The District Court denied McLaughlin’s pro se motions to dismiss for lack of personal jurisdiction; he appealed the denials.
The Second Circuit reviewed the denial de novo and framed the core legal question as when a federal court has personal jurisdiction in a criminal case.
The Court affirmed, holding that when a district court has subject-matter jurisdiction over federal offenses and a defendant is brought before it, the court has personal jurisdiction, regardless of the voluntariness of the defendant’s presence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a federal district court has personal jurisdiction over a defendant charged with a federal crime who is before the court	Court has jurisdiction because of subject-matter jurisdiction and defendant’s presence	Court lacked personal jurisdiction over McLaughlin; federal authority illegitimate	Held: Yes. Personal jurisdiction exists when the court has subject-matter jurisdiction and the defendant is brought before it
Whether voluntariness of the defendant’s presence affects jurisdiction	Voluntariness not required; presence suffices	Forced or nonconsensual appearance defeats jurisdiction	Held: Voluntariness is irrelevant; forcible or involuntary presence does not defeat jurisdiction

United States v. Alvarez-Machain, 504 U.S. 655 (1992) (federal court retains jurisdiction when defendant is brought before it even if apprehension was forcible)
Frisbie v. Collins, 342 U.S. 519 (1952) (forcible abduction does not impair a state or federal court’s power to try a defendant)
United States v. Williams, 341 U.S. 58 (1951) (subject-matter jurisdiction over federal offenses supplies jurisdiction over persons charged)
United States v. Scott, 394 F.3d 111 (2d Cir. 2005) (denial of motion to dismiss indictment reviewed de novo)
United States v. Rendon, 354 F.3d 1320 (11th Cir. 2003) (federal district courts have personal jurisdiction over defendants brought before them on federal indictments)
United States v. Pryor, 842 F.3d 441 (6th Cir. 2016) (federal courts have personal jurisdiction regardless of whether defendant was forcibly brought)
United States v. Burke, 425 F.3d 400 (7th Cir. 2005) (personal jurisdiction supplied by defendant’s presence within U.S. territory)