In Myles v. Thompson, the plaintiffs, Youn-Faa Oliver Myles and Charles Alvah Smith, brought a lawsuit in the United States District Court for the District of Maryland, challenging the taxation of Myles’ Glenwood, Maryland property. The plaintiffs argued that the property was classified as “allodial,” a designation they claimed rendered it exempt from taxation under Maryland law and broader principles of sovereignty. They sought various forms of relief, including a refund for tax payments Myles had allegedly made to avoid a tax sale, compensation for legal work performed by Myles, and an injunction requiring Howard County to recognize the allodial nature of the property.
The plaintiffs framed their arguments within a broad theory of sovereign citizenship, asserting that they were members of a self-styled “Maryland Assembly.” They described this assembly as a collective of individuals with “land jurisdiction,” which they claimed derived from the original inhabitants of Maryland and excluded the state government, which they characterized as having jurisdiction only over “water” or non-land matters. According to their filings, the Glenwood property was integral to their assertion of sovereignty and was to be held in trust for their assembly as evidence of their “lordship” and “allodial title.”
The plaintiffs relied on several legal theories in support of their claims. They invoked federal-question jurisdiction, citing various statutes including 42 U.S.C. §§ 1983, 1986, and 1953, as well as 18 U.S.C. §§ 241 and 242. They also sought to assert jurisdiction under diversity of citizenship, despite being Maryland residents and naming Maryland officials and entities as defendants. In addition to their federal claims, the plaintiffs appeared to raise state-law claims under the Maryland Constitution and Declaration of Rights.
The court dismissed the case on two primary grounds. First, it found that it lacked subject matter jurisdiction. None of the federal statutes cited by the plaintiffs provided a valid basis for federal-question jurisdiction. Some statutes, such as 18 U.S.C. §§ 241 and 242, are criminal statutes that do not create private rights of action. Others, such as 42 U.S.C. § 1986, depend on a viable claim under 42 U.S.C. § 1985, which the plaintiffs had not established. The plaintiffs’ references to allodial title and their assertions of sovereignty did not constitute a valid federal controversy, as courts across the country have consistently rejected such claims as frivolous.
Second, even assuming the court had jurisdiction, it found that the plaintiffs failed to state a claim upon which relief could be granted. Their primary contention—that the property’s allodial status exempted it from taxation—was legally baseless. The court emphasized that U.S. law does not recognize private claims of allodial title in the modern context, and no American state or federal court has ever acknowledged such a defense against taxation. The plaintiffs also failed to demonstrate a constitutional violation or any actionable wrongdoing by the defendants.
The court dismissed the case with prejudice, noting that the plaintiffs had already amended their complaint and that further amendments would be futile. In doing so, the court declined to address alternative arguments for dismissal, including sovereign immunity and improper service, as the lack of jurisdiction and failure to state a claim were dispositive. The dismissal with prejudice reflected the court’s view that the plaintiffs’ legal theories were fundamentally flawed and could not be salvaged through further litigation.
Myles v. Thompson, 2024 U.S. Dist. LEXIS 233118, Civil No. 24-1710-BAH (D. Md. Dec. 27, 2024)