In United States v. Thody, 2025, the Sixth Circuit Court of Appeals upheld the 12-month prison sentence of Daniel Isaiah Thody, a convicted tax evader and self-proclaimed sovereign citizen, following his third revocation of supervised release. The ruling reinforced the judiciary’s longstanding rejection of sovereign citizen legal theories, particularly their attempts to avoid financial and legal responsibilities through pseudo-legal tactics.
Thody’s Crimes and Initial Conviction
Thody’s legal troubles began with his refusal to report income to the IRS, a hallmark of sovereign citizen ideology. In 2013, he was convicted in the Western District of Texas on five counts of tax evasion, each carrying a maximum sentence of 60 months in prison. The court sentenced him to a total of 90 months’ imprisonment, structured as consecutive 45-month terms for two counts and concurrent 41-month terms for the remaining three. Additionally, he was ordered to serve three years of supervised release and, after a remand, to pay $162,037 in restitution to the U.S. government.
Supervised Release and Sovereign Citizen Defiance
Thody began his supervised release in September 2019, but rather than comply with the court’s restitution order, he immediately engaged in sovereign citizen tactics to avoid payment. He attempted to settle his debt using fraudulent financial instruments labeled as “dollars,” a known tactic of sovereign citizens who falsely claim they can discharge debts using fictitious currency or promissory notes. Additionally, he refused to provide financial disclosure forms to his probation officer, falsely asserting that the federal government had no authority over him.
In response to these violations, the district court revoked Thody’s supervised release in April 2021, sentencing him to six months in prison and imposing an additional 24 months of supervised release. The court reiterated that he was still responsible for the full restitution amount and must comply with financial reporting requirements.
Escalating Defiance and Further Revocations
After completing his second term of imprisonment, Thody resumed his defiance upon reentering supervised release in October 2021. He informed his probation officer that he did not recognize the authority of the court and would not make restitution payments. When ordered to submit a net-worth statement, Thody wrote “5th Amendment Invoked” on every answer, a tactic frequently used by sovereign citizens to obstruct financial investigations.
The probation officer petitioned the court to revoke Thody’s release again, which the court granted. This time, the court extended his supervised release to 30 months. Thody appealed, arguing that extending his supervised release exceeded the statutory maximum sentence for tax evasion, but the Sixth Circuit upheld the court’s decision.
Final Revocation and Appeal
In January 2024, Thody committed another set of violations, including:
- Failing to submit monthly supervision reports
- Failing to notify probation that he had been questioned by law enforcement
- Failing to provide required financial information
In response, the district court revoked his supervised release a third time, sentencing him to 12 months in prison with no additional supervised release. During the revocation hearing, Thody pleaded not guilty, claiming that the district court lacked jurisdiction and that supervised release could only be imposed with his consent. However, he admitted that the violations had occurred but continued to assert that the government had no legal authority over him.
In his appeal, Thody continued to rely on sovereign citizen legal theories, arguing that:
- Supervised release is unconstitutional and can only be imposed as a reduction of imprisonment, not as a separate sentence.
- Any revocation sentence exceeding the original statutory maximum for tax evasion violates the Fifth and Sixth Amendments.
- Federal sentencing statutes (Title 18) do not apply to tax-related offenses under Title 26, attempting to claim that tax laws operate independently of general federal criminal law.
Sixth Circuit’s Rejection of Sovereign Citizen Claims
The Sixth Circuit unequivocally rejected all of Thody’s arguments, reaffirming that supervised release is a separate component of federal sentencing and that courts have full authority to revoke and reimpose it. The court cited longstanding precedent confirming that supervised release is not equivalent to parole, as sovereign citizens often claim. Instead, a court may revoke release and impose further imprisonment if violations occur, without violating constitutional protections.
The panel also dismissed Thody’s reliance on Supreme Court rulings, including Johnson v. United States and United States v. Haymond, finding that neither case supported his claims. Moreover, the court explicitly rejected Thody’s assertion that tax laws are immune from general sentencing statutes which applies all federal sentencing provisions to any federal offense unless explicitly stated otherwise.
Court’s Final Statement: “The Law Must Prevail”
In upholding Thody’s sentence, the court addressed his deeply held sovereign citizen beliefs, acknowledging that while he may be personally convinced of his theories, his convictions do not override the law. The district court had already warned Thody that personal ideology does not exempt individuals from legal responsibilities, stating that “when those principles and convictions conflict with the requirements of the law, the law must prevail.”
Source: United States v. Thody, 2025 U.S. App. LEXIS 2838 (6th Cir. 2025).