There are so many sovereign citizen cases that never make the news. There are many reasons for this and sometime, I will write about them. Here is a case I found today.
In the case of Butts v. Clarke (2025 U.S. Dist. LEXIS 1198) Corey Lee Butts (of Virginia) filed a pro se habeas corpus petition challenging his convictions on several charges: maliciously discharging a firearm into an occupied building, aggravated malicious wounding, use of a firearm in the commission of a felony, and reckless handling of a firearm resulting in serious injury. These charges stemmed from a 2016 shooting at a convenience store in Norfolk, Virginia.
The incident involved a shooting outside a convenience store that injured a bystander. Surveillance footage captured a man firing a gun, with the victim later being treated for a gunshot wound. Witness testimony identified Butts as the shooter, corroborated by physical evidence, including video recordings from the crime scene and subsequent footage of Butts outside the store two days later. He was convicted by a jury in 2019 and sentenced to 25 years in prison, with three years suspended.
In his federal habeas petition, Butts identified himself as a “Moorish American,” a “natural person,” and a “flesh-and-blood human being” not subject to the jurisdiction of Virginia courts. He further alleged that the court failed to prove jurisdiction or adhere to the principle of corpus delicti, claiming that no victim or body was presented in evidence.
The court unequivocally rejected these claims, citing long-standing precedent that sovereign citizen defenses lack any basis in American law. The court noted that a person’s self-declared status—whether as a “Moorish American” or any other claimed sovereign designation—does not exempt them from legal accountability or court jurisdiction. The court referenced cases such as United States v. White and United States v. Benabe, which emphasizes that citizenship or descent does not alter a court’s jurisdiction in criminal prosecutions.
Beyond the substantive claims, Butts’ habeas petition was deemed untimely. Under the Anti-Terrorism and Effective Death Penalty Act (AEDPA), habeas petitions must be filed within one year of a conviction becoming final. Butts’ conviction became final in November 2021, but he did not file his federal petition until August 2023—eight months after the statute of limitations had lapsed.
Butts argued that his appellate counsel abandoned him, but the court found no evidence that this prevented timely filing. Instead, Butts had spent time filing non-judicial complaints against his counsel with the Virginia State Bar and other bodies, none of which legally tolled the deadline. His claims of “actual innocence,” predicated on procedural arguments rather than new exculpatory evidence, also failed to meet the stringent standards required to bypass procedural bars.
The court dismissed Butts’ petition with prejudice, stating that his sovereign citizen claims were frivolous and without merit. It also denied a certificate of appealability, indicating that no reasonable jurist would debate the procedural or substantive rulings. The dismissal reinforced the principle that courts are not obligated to entertain baseless challenges to their jurisdiction.