Sovereign Citizen in Federal Case Loses Appeal

Frank Ray Berris, a self-identified “state national” aligned with sovereign citizen ideologies, landed in legal trouble after a dramatic traffic stop on U.S. Highway 20/26 in Wyoming on February 3, 2024. A trooper discovered three loaded firearms in Berris’s unregistered, uninsured vehicle—a 9mm Smith & Wesson pistol, a Ruger SR-556 rifle, and a .45-caliber Colt pistol. Given Berris’s prior felony convictions, including three for unlawful firearm possession. The stop escalated into a three-hour standoff, with Berris refusing to exit his vehicle, stating, “You’re going to have to kill me,” leading officers to close the highway.

Representing himself, Berris rejected the court’s jurisdiction and federal laws, embracing sovereign citizen rhetoric. The district court barred him from presenting this defense or arguing his beliefs to the jury, deeming them irrelevant. Berris also tried to challenge his prior convictions and claimed ignorance of his felony status, citing a 2022 Border Patrol encounter where an agent allegedly said his record was clear under “international law.” The court dismissed these arguments, pointing to Berris’s prior guilty pleas and a 2019 denied firearm purchase due to a background check, proving he knew his status. After a two-day trial, a jury convicted Berris, and he was sentenced to 90 months in prison, followed by three years of supervised release.

Berris appealed to the Tenth Circuit, reiterating his sovereign citizen claims and arguing the district court wrongly excluded evidence, like his 2022 state acquittal, and that the government failed to prove he knew his felony status barred firearm possession. He also claimed no crime existed without an “injured party.” On May 12, 2025, the Tenth Circuit affirmed the conviction, finding no abuse of discretion in the district court’s rulings.

Source: 2025 U.S. App. LEXIS 11382 (10th Cir. May 12, 2025).

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