In the case of People v. Branton, decided on May 29, 2025, by the Supreme Court of New York, Appellate Division, Third Department, Rodney Branton appealed his conviction for offering a false instrument for filing in the second degree, a charge rooted in his actions as a self-proclaimed “sovereign citizen.” The case centered on Branton’s filing of false liens against the Acting Commissioner of the Department of Corrections and Community Supervision (DOCCS) and two judicial officers, asserting they owed him a debt based on his belief that, as a sovereign citizen, these officials lacked authority over him. This belief, commonly associated with the sovereign citizen movement, posits that individuals can declare themselves independent of government authority, often leading to the filing of fraudulent legal documents to challenge or harass public officials.
The investigation began when DOCCS was notified of liens filed with the Department of State, listing Branton as the creditor to the victims. A DOCCS investigator confirmed the liens’ existence and found no legitimate financial basis for them. During a non-custodial conversation at Branton’s residence, he admitted to filing the liens to put the victims “on notice” that they had no right to exercise authority over him, explicitly tying his actions to his sovereign citizen ideology. The victims testified they had no personal or business dealings with Branton, reinforcing the falsity of the liens. The jury convicted Branton of the lesser included offense of offering a false instrument for filing in the second degree, and he was sentenced to nine months in jail.
Branton’s appeal challenged the weight of the evidence, arguing the prosecution failed to prove he knowingly filed false documents with intent for them to become part of public records. The court rejected this, finding that Branton’s admission, coupled with the victims’ testimony and the investigator’s findings, demonstrated his awareness of the documents’ falsity and his intent to file them as a sovereign citizen tactic to assert fictitious claims. The court deemed the verdict amply supported, noting a different outcome would have been unreasonable.
Branton also raised speedy trial and suppression issues. He argued the prosecution’s certificate of compliance (COC) was invalid due to undisclosed disciplinary records of the DOCCS investigator and that the COC was filed beyond the six-month speedy trial period. The court dismissed these claims, noting that DOCCS is not a law enforcement agency for discovery purposes, so the records were not subject to mandatory disclosure. Additionally, a 45-day delay caused by Branton’s requests for judicial reassignments was excluded, bringing the prosecution’s prereadiness delay within the statutory limit. On the suppression issue, Branton’s statements to the investigator were deemed admissible, as the interaction was non-custodial, occurring voluntarily in his bedroom without restraint, negating the need for Miranda warnings.
The Appellate Division affirmed the conviction, underscoring how Branton’s sovereign citizen beliefs drove his criminal conduct but did not absolve him of legal accountability. The case highlights the judiciary’s rejection of sovereign citizen tactics, particularly the misuse of false legal documents to challenge governmental authority.
Reference: People v. Branton, 2025 N.Y. App. Div. LEXIS 3291 (2025).