In Buchanan v. State, the Indiana Court of Appeals affirmed the conviction of Stacey Buchanan, a self-identified sovereign citizen, for Class A misdemeanor resisting law enforcement. The case arose after Buchanan was pulled over in Indianapolis on March 30, 2024, for displaying a fictitious “EXEMPT” license plate, which the arresting officer recognized as commonly used by sovereign citizens attempting to evade state jurisdiction. Buchanan refused to provide identification or comply with lawful orders, telling Officer Jacob Scheid that the plate was intended to “avoid being bothered by the police.”
Despite repeated requests, Buchanan refused to exit her vehicle. When officers attempted to remove her, body camera footage showed Buchanan initially allowed her left arm to be guided outside but then re-centered herself in her seat. She then braced her right knee between the steering wheel and the center console and grasped the steering wheel with her hand, physically preventing officers from pulling her out. Officers eventually removed her from the vehicle and placed her under arrest. Along with resisting arrest, she was charged with driving while suspended, operating a vehicle with a fictitious plate, and refusal to identify herself. A marijuana dealing charge was later dismissed.
On appeal, Buchanan argued that the evidence did not support a finding of forcible resistance claiming that her actions lacked the necessary strength or aggression. However, the appellate court found her behavior went beyond mere passive resistance. By physically wedging herself and gripping the wheel, Buchanan created a standoff and impeded officers through active and intentional force. The court emphasized that even modest but deliberate resistance—such as bracing or leveraging body weight—can constitute forcible resistance when it interferes with law enforcement duties.
This case underscores how courts treat sovereign citizen defiance, especially when it escalates into physical interference. Despite Buchanan’s belief that her fictitious plate shielded her from state authority, the court found that her resistance was clear, deliberate, and sufficient to uphold her conviction. As the court succinctly put it: “the body cam tells the tale”—and in this case, it told one of obstruction, not sovereign immunity.
Source: Buchanan v. State, No. [not provided], Ind. Ct. App. 2025.