In People v. Coates, the Michigan Court of Appeals overturned the sentencing of Christy Love Coates, a woman convicted of driving while her license was suspended.
Coates’ legal troubles began in November 2022 when a police officer in Warren, Michigan, pulled her over for excessive window tint. During the stop, law enforcement discovered a pistol and two magazines loaded with ammunition. Prosecutors charged her with driving while her license was suspended (DWLS), second offense, as well as carrying a concealed weapon (CCW) without a permit.
At trial, Coates did not deny that she was operating a vehicle without a valid license. Instead, she attempted to justify her actions by arguing that she was “traveling” in her private vehicle rather than “driving,” a term she claimed applied only to those engaged in commercial activities. According to Coates, her research into Supreme Court precedent led her to conclude that she was not required to obtain a license to use public roads for personal travel.
Despite her arguments, the jury found her guilty of the DWLS charge but acquitted her of the CCW charge. Since she was convicted of only a misdemeanor offense, Michigan law presumes a nonjail sentence, typically involving fines or community service. However, at sentencing, the trial court departed from this presumption and sentenced Coates to 93 days in jail, citing concerns about her refusal to recognize the legitimacy of the law.
The prosecution played a key role in pushing for a harsher sentence, arguing that Coates’ trial testimony demonstrated her unwillingness to abide by Michigan law. The prosecutor also repeatedly referenced the CCW charge, despite the jury’s acquittal, suggesting that Coates was likely still carrying a firearm unlawfully.
The trial court justified the departure from sentencing guidelines by asserting that Coates had been “brainwashed” by the sovereign citizen movement and that her refusal to recognize the authority of the law made rehabilitation unlikely. The judge compared her resistance to obtaining a driver’s license with her refusal to obtain a concealed pistol permit, emphasizing that legal pathways existed for both but that she chose not to follow them.
From the court record: 
On appeal, the Michigan Court of Appeals ruled that the trial court failed to justify why a jail sentence was proportionate to the offense. The court also determined that the trial judge improperly considered acquitted conduct in imposing the sentence, violating the principle that defendants should not be punished for charges a jury has rejected. As a result, the appellate court vacated Coates’ sentence and remanded the case for resentencing, instructing the lower court to impose a sentence within the legal framework and without reference to the CCW charge.
The case highlights ongoing tensions between the legal system and sovereign citizen defendants, as well as the responsibility of courts to ensure that even those with fringe legal views receive fair treatment under the law.
Citation: People v. Coates, 2025 Mich. App. LEXIS 1498 (Mich. Ct. App. Feb. 25, 2025).