key: cord-351732-wws6ring
authors: Sarteschi, Christine M.
title: Sovereign Citizens: A Narrative Review With Implications of Violence Towards Law Enforcement
date: 2020-09-24
journal: Aggress Violent Behav
DOI: 10.1016/j.avb.2020.101509
sha: 
doc_id: 351732
cord_uid: wws6ring

Extremist movements are growing in the United States. One concerning extremist group is that of sovereign citizens. Sovereign citizens have been labeled by the Federal Bureau of Investigation as a terrorist threat. Relative to other research about extremist groups, limited research exists about the sovereign citizen movement. The purpose of this article is to review all relevant literature concerning this movement, as it pertains to the threat posed to law enforcement, via descriptive research and to identify existing knowledge gaps. Most empirical work, about sovereign citizens, thus far has focused on legal matters, mental health, radicalization, and postdiction of targeted violence. The work presented here serves as a foundation for future research concerning this group.

The DHS definition is narrower and focuses only on sovereign citizen extremists which they define as "groups or individuals who facilitate or engage in acts of violence directed at public officials, financial institutions, and government facilities in support of their belief that the legitimacy of the U.S. citizenship should be rejected, almost all forms of established government, authority, and institutions are illegitimate and that they are immune from federal, state and local laws" (U.S. Department of Homeland Security, 2014, p. 1). The DHS seems focused on sovereign citizens who engage in violence, as opposed to those who may believe in violence philosophically, but who have yet to engage in violence.

This paper defines sovereign citizens in accordance with the FBI and the DHS. This paper also takes the position that any individual who is legally considered to be a citizen of the U.S. and who simultaneously believes that the U.S. is not a legitimate government, and as a result of that illegitimacy, believes themselves to be immune to all U.S. laws, is to be considered a sovereign citizen. These defined individuals may refer to themselves as something other than sovereign citizens and often do. One does not need to consider themselves a sovereign citizen to be a sovereign citizen. Other names sovereigns may call themselves include: freeman on the land, flesh and blood human being, natural man, free person, sovereign man, layman, a natural person, a freedom of common-law citizen, and other names. The core belief of sovereign citizens, is their proclaiming the American government to be illegitimate. on the land," and a number of political candidates have made claims and have utilized tactics seemingly consistent with the sovereign citizen movement (Baldino & Lucas, 2019) . In June 2020, four members of a sovereign group "New Westralia" broke into a historic courthouse and took up residence (Hedley, 2020) . Social media posts indicated that their goal was to establish themselves as the "proper governing body of law for Western Australia" (Hedley, 2020, para. 7) .

In another example involving Australia, Mark Pytellek, a well-known sovereign citizen and his wife, were running a Facebook group crusading against a new rule mandating flu vaccines for those who were visiting individuals in aged care homes (Wilson, 2020) . The couple was selling an online service that charges a fee to add their name to a form letter titled "Vaccine Non Consent Document Creator" to be sent to Australian officials (Wilson, 2020) . In addition, they are also encouraging users to pay $69.99 annually for access to a website called Solutions Empowerment that teaches sovereign rights and other secret strategies (Wilson, 2020) . Mr.

Pytellek has a record of legal trouble with authorities in Australia.

In a video from Singapore, dated May 2020, there appears to be a sovereign citizen female yelling "I am not a person, I am sovereign" when confronted by police for refusing to wear a mask in public and for breaching safe social distancing measures, under COVID-19 regulations (Koay, 2020) . In Russia, individuals calling themselves "citizens of the U.S.S.R." or "soviet citizens" are claiming they do not have to follow the laws of the Russian federation nor do they recognize it as a legitimate legal body (Luxmoore, 2019). Much like the sovereign citizen movement in the U.S., many "soviet citizens" are learning how to supposedly evade laws via the internet. YouTube, in particular, has channels with thousands of followers (Luxmoore, 2019).

One popular channel claims to offer "practical tips and advice for citizens of the USSR" in how J o u r n a l P r e -p r o o f Journal Pre-proof they can "legally avoid paying off debt" (Luxmoore, 2019, para. 14). That video, as of May 2019, had 2.8 million views (Luxmoore, 2019).

Germany's version of the sovereign citizen movement is known as Reichsbürgers or the Reich Citizens movement. Estimated to number approximately 19,000 individuals, across the country, they believe the laws of both Imperial Germany and Nazi Germany still apply (The Sun, 2020) . They also print their own passports, refuse to pay taxes and engage in paper terrorism (Gauvery Herbert, 2020) . Some are prone to violence. Former Mister Germany, Adrian Ursache, a prominent member of the Reich Citizens movement, shot and killed a police officer in 2016.

He had declared his property an independent state and when police tried to evict him from his "independent state" he attempted to kill them (The Sun, 2020). Two months later, one of Urache's followers, Wolfgang Plan, shot at police as they attempted to remove his weapons. One officer died and two officers were injured during the incident. Mr. Plan was sentenced to life in prison.

One exceptional Reichsbürger case is that of Peter Pitzek. He refers to himself as the King of Germany, and claims dominion over 1,300 subjects (Gauvey Herbert, 2020) . He was able to convince dozens of individuals to live on a compound in Wittenberg, Germany. They all gave him money, some their entire life savings. He amassed millions of dollars. He opened his own bank and was collecting deposits until German authorities shut it down. Upon investigation, the authorities were only able to locate a small amount of money on his property. Investigators concluded that the self-proclaimed King of Germany had spent most of the money on himself, in the form of travel, cars and real estate. The rest, they estimated, had been laundered through a network of companies and then hidden in countries that lacked extradition treaties with J o u r n a l P r e -p r o o f Journal Pre-proof Germany. He went to trial and was convicted. None of the money was ever recovered. After about a year in prison, an appeals court overturned his conviction. No longer incarcerated, he has since acquired new money-making ventures. More than 70 companies, for a fee, have incorporated in his kingdom. Much like in Australia, members of the far-right political establishment in Germany have been adopting some of the language of the Reichsbürger movement, suggesting that these ideas have gone mainstream. German authorities have been trying to crack down on the illegal activities of the Reichsbürgers, but only with limited success (Gauvey Herbert, 2020).

Sovereign citizen-hood is spread via the Internet, particularly on YouTube. There are millions of videos on the topic. The sovereign citizen message is also spread through jails and prisons, typically via mailers and word of mouth. The Marshall Project described a sovereign citizen scheme operating in prisons. Legitimate-sounding companies claim that the U.S. government is holding all prisoners for financial reasons and that for an initial fee of $4000, they will initiate a bond process that will ultimately earn a prisoner their freedom (Thompson, 2019) .

Bond process, also known as straw man, redemption or accepted for value schemes, involve the use of fraudulent financial documents that appear legitimate (FBI, n.d.) . Many unsuspecting victims find out, after the fact, that the bond process is simply an illegitimate money-making scheme.

A number of high-profile individuals have attempted to use sovereign citizen strategies in courts, but none have been successful. One example is Jared Fogle, the former spokesperson for the Subway sandwich restaurant chain, who declared himself a sovereign citizen in court filings.

In one instance, he was attempting to correct an "error" regarding subject matter jurisdiction, essentially questioning the court's authority to render a verdict (Bever, 2017) . Mr. Vogel pled guilty, in 2015, for receiving child pornography and for traveling and attempting to elicit sexual conduct with a minor. He was sentenced to 15 years in federal prison (Bever, 2017) . All of his sovereign citizen arguments have been deemed frivolous and rejected by the court (Evans, 2017) .

Some learn about the many supposed advantages of sovereign citizen-hood via a number of gurus peddling seminars, promising the ability to emancipate oneself from the federal government (Pitcavage, 2012) . For instance, The New York Times profiled Sean David Morton, a sovereign citizen who taught workshops claiming instant debt relief from mortgages, tax bills and student loans (Powers, 2019). David Wynn Miller, another tax protester/sovereign citizen guru, and his adherents, claimed that the government cannot tax their income because they are individuals without citizenship and thus are sovereign unto themselves (United States v. Kriemelmeyer, 2006) . Mr. Wynn Miller went a step further than many other gurus and invented his own dialect called "In the Truth." This dialect, he claimed, is based on mathematics, and is characterized by an overuse of prepositional phrases, hyphens, and colons and avoids the use of verbs, pronouns, adjectives, and adverbs (United States v. Kriemelmeyer, 2006) . Mr. Wynn Miller has since passed away but his tactics live on and are attempted by other sovereign citizens. syndrome (SIDS) and became angry at the government after they insisted upon an autopsy. He subsequently became involved with the Dorean group, a company much like Sean David Morton's company, who offered seminars about debt relief and gaining freedom from government. Mr. Kane initially was a strong supporter of the Dorean group, promoting their materials, but that changed after experiencing a number of legal problems. He eventually quit the group and started his own seminars. His seminars often included his advocating extreme violence, including the killing of Internal Revenue Service (IRS) agents. His violent rhetoric prompted the FBI to open an investigation. He increasingly has had more run-ins with law enforcement. His son Joseph took a similar stance against the government. Even as a young child, he had trouble with the law and was known to be disrespectful, problematic and defiant (Carson, James, & O'Neil, 2019) . actions. Their results indicated that the TRAP-18 measure successfully distinguished between sovereign citizens who were violent from those who were not. The researchers found that individuals with higher TRAP-18 scores were two times more likely to be involved in committing an act of violence compared to those with lower scores. Six warning behaviors (pathway, identification, novel aggression, energy burst, leakage, and last resort) and four distal behaviors (personal grievance, framed by ideology, greater creativity, and criminal violence) significantly postpredicted violence in their research (Challacombe and Lucas, 2019).

For those unfamiliar with sovereign citizens, their behavior can seem odd, bizarre, confusing, and seemingly indicative of mental illness. This may explain why judges, after dealing with their disruptive behavior in the courtroom, frequently request mental health evaluations, to determine competency. In the literature, there are four studies to date, regarding the mental health of sovereign citizens and their fitness to stand trial. All of them seem to suggest that the vast majority of sovereign citizens are not mentally ill and are competent to stand trial.

Pytyck and Chaimowitz (2013) took a case study approach, while analyzing two cases of sovereign citizens who were referred to the court for mental health assessment. One was a male and one was a female. In both cases, they refused to cooperate with officers before their arrests and were uncooperative in court, thus prompting their competency evaluations. Both were deemed competent to stand trial. The authors argue that, in their view, the majority of sovereign citizens are not psychotic and are fit to stand trial. J o u r n a l P r e -p r o o f Journal Pre-proof Parker (2014) conducted a retrospective study regarding competence among sovereign citizen defendants undergoing psychiatric evaluations. In this study, he reported the results of nine cases of individuals, identified as sovereign citizens, who were court-ordered to undergo evaluations of competence to stand trial. Of the nine, three refused to participate in clinical interviews. Their average age was approximately 39 years old, had at least a high school education. The majority were African-American and eight of the nine defendants were male.

Though two of the six had histories of mental health treatment, none showed significant cognitive deficits or had any history of psychosis. One defendant received a diagnosis of delusional disorder and another for depression. Three received diagnoses of substance abuse disorders; one had no diagnosis. The defendant who received the delusional disorder diagnosis was deemed incompetent to stand trial, however, Parker later came to believe that this defendant did not truly meet the criteria for delusional disorder and was competent to stand trial. In his view, those who adhere to the sovereign citizen belief system are mostly likely not delusional and are instead, exhibiting an extremist political philosophy. Parker argues that being a sovereign citizen alone is not enough to warrant a mental health diagnosis or a judgment of incompetence (Parker, 2014) . four studies available, thus far, support the notion that the majority of sovereign citizens are not diagnosably mentally ill or unfit to stand trial. Sovereign citizens who are diagnosably ill and thus unfit to stand trial, are the exception rather than the rule. More research is needed to understand why sovereign citizens adopt such extremist beliefs.

A good deal of information about sovereign citizens was found in legal review articles. Four legal articles were identified through this review. Perhaps one of the most cited articles, in U.S. legal opinions, was by Loeser (2015) which provides a thorough examination of sovereign citizens as paper terrorists, the problems they cause in the courtroom and the danger they pose to public officials. Loeser (2015) recommends a number of legal and educational solutions for stopping the sovereign citizen threat including deterrence through effective punishment, prefiling injunctions, procedural justice, online activism, and education about the history of government. Likewise, the remaining articles (Kalinowski, 2019) educate the reader about the nature and beliefs of sovereign citizens, in addition to examining the rationale for why sovereign citizens often wish to represent themselves in court (Phillips, 2019).

The most expansive and thorough article was that of Netolitsky (2018) Of the 30 cases, 40% were perpetrated by either antigovernment offenders or those who were sovereign citizens, though the researchers did not specify which of the 40% were sovereigns and which were merely labeled antigovernment. Their analysis also revealed that the family members of sovereigns often share the same belief system, are typically armed and may be willing to use deadly violence against law enforcement (Gruenewald et al., 2016) .

In an effort to examine that threat more closely, open-source information was searched to capture instances when: 1) sovereign citizens attempted to harm, did harm or who killed LEOs;

and 2) sovereign citizens who threatened to harm LEOs. The focus on all forms of violence directed at police, including those who make threats, was collected in an attempt to gain a fuller picture of the dangers faced by LEOs from sovereign citizens. Sierra-Arévaloa and Nix (in press), for instance, found that between 79 and 86 percent of firearm assaults on police do not which curates and archives legal news and court cases. Table 1 shows that of the 75 instances in which sovereign citizens attempted to harm or did harm LEOs, there were 27 LEOs killed by sovereign citizens between 1983 and July 2020.

Officers killed at traffic stops, accounted for eight of the 27 (30%) deaths. Eight officers (30%) were killed during ambushes, six officers (22%) were killed during police standoffs, four officers' (15%) deaths occurred while doing routine checks or serving a warrant, and one officer (3%) was killed in a gun battle in a grocery store parking lot.

Insert Table 1 here Aside from the 27 deaths, there were an additional 65 LEOs who were wounded. Many of the sites of the violence were traffic stops, ambushes, courthouses, parking lots, and others.

Examples of the violence, ranged from a police officer who had his thumb bitten off, to an officer shot and wounded at a gas station. In another incident, December, 2018, a sovereign J o u r n a l P r e -p r o o f Journal Pre-proof citizen was pulled over for failing to come to a stop at multiple stop signs. Upon requesting her driver's license, the driver stated that she did not need a license because she was not "trafficking goods nor at commerce," a common claim among sovereign citizens (Pennsylvania v. Smith, 2020, para. 3). She did provide a self-created identification card and claimed to be an American National. After questioning the officer's authority, she was asked to exit her vehicle, a request that she refused (Rellahan, 2020) . While attempting to forcibly remove her from the vehicle, an officer's arm became entangled with hers as she drove away, dragging the officer 10 to 15 feet (Pennsylvania v. Smith, 2020) . She then fled, driving at a high rate of speed, eventually being apprehended. After a three-day trial, she was convicted of aggravated assault (Rellahan, 2020) .

Some of the cases involving sovereign citizens attacks on LEOs are quite unusual and elaborate. Consider the case of Gregory Lee Rodvelt. In September 2018, law enforcement arrived at the scene of his home in Williams, Oregon. According to the affidavit, the team soon learned that Mr. Rodvelt had booby-trapped the property (United States v. Rodvelt, 2018) . Upon arrival the officers approached a gate. They noticed a circular hot tub spa that was rigged in such a way that opening the gate would activate a mechanical trigger propelling the spa to roll towards the person opening the gate. Observers described the apparatus akin to something from the Indiana Jones movie Raiders of the Lost Ark. They also noticed another unusual apparatus on one of the overhead garage doors: a wooden mouse trap, rigged to discharge a shotgun blast if the garage door were to be lifted. Law enforcement then moved forward to gain entry into the property. Inside, they would find more booby-traps. Upon entry, they were surprised by a wheelchair rolling towards them. It then exploded and fired a shotgun shell that hit an FBI agent J o u r n a l P r e -p r o o f Journal Pre-proof in the leg. The affidavit noted that Mr. Rodvelt had previously been arrested for domestic violence, DUI, aggravated assault, and possession of explosives and destructive devices. He had no felony convictions at the time of his latest incident.

In September of 2010, the local county sheriff and two employees of a petroleum company knocked on the door of Mr. White (CNN Wire Staff, 2010) . They wanted to speak to him about an oil well on his property and inform him that the company owned mineral rights to his land (Mustian, 2010) . Mr. White had been blocking the company's access roads and leaving notes expressing his unhappiness with the company using certain chemicals to kill weeds (Mustian, 2010) . It was his view that they had been poisoning his water (Mustian, 2010) . Upon seeing the deputy at his door, Mr. White began shooting, hitting the deputy three times and also News reports indicate that Mr. White had a volatile history. He was attracted to guns at a young age (Mustian, 2010) . He liked to practice quick drawing, once even shooting himself in the leg (Mustian, 2010) . He joined the military and after his service, worked with his brothers as a pipe layer (Mustian, 2010) . Eventually, he was hurt on the job and began living off the money he collected as part of a civil settlement from the injury (Mustian, 2010) . Newspaper accounts indicate that he had been arrested in 1993 and charged with kicking in a door (Mustian, 2010) .

It was also around that time that he began refusing to pay property taxes on his land. He complained to his family that drivers' licenses were "unconstitutional" and once pled guilty to driving without a license (Mustian, 2010) . He was sued by the school district and other taxing entities. He responded by filing court documents containing various nonsensical antigovernment articles and a bumper sticker that read "fight organized crime, abolish the IRS" (Mustian, 2010) .

He would also visit the district's clerk's office, distributing flyers printed by the "Citizens Crime

Commission" (Mustian, 2010) . The flyers were meant to warn public officials about his contention that they were violating the law and would be standing trial for their crimes. The district's clerk's office hired a security guard and installed a panic button after Mr. White explicitly threatened to kill all of their lawyers. (Mustian, 2010) . In a 2010 interview, while in jail after his arrest, Mr. White stated that he planned to retaliate against law enforcement via civil lawsuits and reiterated his hatred for law enforcement (Mustian, 2010) . In December 2012, he was sentenced to life in prison plus 20 years (Vanderlaan, 2012) .

Even in cases where no officer was harmed by sovereign citizens, deadly force was often intended. In March 2018, a vehicle in Minnesota slid off the road due to poor weather conditions. Troopers stopped to assist the two Moorish sovereign citizen occupants and soon learned that the vehicle had been reported stolen. As one of the troopers began to handcuff the male suspect, the female suspect held a 9mm handgun to his head and pulled the trigger. The gun misfired and no bullet exited the chamber. The trooper acquired his weapon and shot the female suspect in the arm as she ran off. It was later learned she had an active arrest warrant for sex trafficking, along with a history of drug convictions (Delong & Sanchick, 2018).

In an unusual case involving a "free citizen," (another name for a sovereign citizen), a man refused to leave a mall parking lot. The police determined that he had a revoked driver's license and a warrant for his arrest. The situation escalated when he refused to leave his vehicle. Upon inspection, the police recovered "a device from the RV that was shaped like a pig and had '(expletive) the police' written on it. The pig held an energetic powder and appeared to be an explosive device" (Venzer, 2019) . The man also specifically stated that he would kill multiple officers (Venzer, 2019) . No one was harmed in the incident but the threat of harm explicitly directed at LEOs was ever present.

Such was the case with James Michael Tesi, a "natural living being," who referred to himself as Tesi El of the Moorish National Republic (Pitcavage, 2012). Mr. Tesi is thought to be the only known Caucasian Moor. He has a history of problematic interactions with police due to his belief in "sovereign freedom to travel." Additionally, he did not think it necessary to follow other traffic laws. He violated seat belt laws, speed limit laws and refused to pay his traffic tickets (Slater, 2016, p. 1) . In his latest confrontation with police (July 2011} court records indicate that Mr. Tesi was driving, when police attempted to pull him over for outstanding warrants (Tesi v. Texas, 2014) . Mr. Tesi swerved around the police vehicles and drove to his home and parked in his garage (Tesi v. Texas, 2014) . Police approached Mr. Tesi who was still in his truck. Mr. Tesi kicked open his driver's side door, armed with a gun, and began firing at the officer. Gunfire was exchanged and Mr. Tesi was shot in the leg. The police officer was not hit but could have easily been killed or seriously injured in the shootout.

In another instance that could have been deadly for law enforcement, an officer pulled over Sovereign citizen deadly violence against LEOs, has also occurred during the course of an ambush. In this research, Table 1 (Etters, 2015). The first deputy on the scene was Chris Smith who was shot immediately upon arrival (Etters, 2015). Another officer was shot but survived because of his bulletproof vest.

People who knew Mr. Holley, reported that he had repeatedly spoken about his intention to kill as many LEOs as possible. He was known to be volatile, to hate the government and to read propaganda online (Etters, 2015) . An investigation revealed that two weeks prior to the shooting, Mr. Holley had explicitly threatened to shoot LEOs if they came to his residence (Rossman & Portman, 2014) . The day before the shooting, his ex-girlfriend had called local authorities to report his threats (Etters, 2015) . None of that information was shared with first responders (Rossman & Portman, 2014) . Table 2 documents 19 instances in which sovereign citizens threatened to harm law enforcement. Some sovereigns made threats in the course of an armed standoff or in elaborate plots designed to target law enforcement, some willing to die for their cause. David Allen Brutsche and Devon Campbell Newman, for instance, plotted to kidnap a LEO and hold their victim hostage in a makeshift jail. After the kidnapping, the duo planned to hold a trial and then "put a bullet in his head" (Powers, 2015, para. 6) . "I'm willing to give my life for this" (Powers, 2015, para. 1). Undercover officers thwarted their plan before it could be carried out (Valley, 2013) .

Insert Table 2 here J o u r n a l P r e -p r o o f Some sovereigns brazenly contact law enforcement and explicitly threaten them via a phone call, private social media messaging or by posting it on public social media accounts.

Such was the case for Michael Hall who was cited by the police for driving an unregistered and uninsured vehicle (LaBella, 2018) . He sent them private messages, putting the police "on notice" for their having violated his constitutional rights, writing that he will "travel freely upon any public road in any public highway I please until the day I die" and that he had "the right to kill a cop (LaBella, 2018, para 2 and 3). In another instance, Mitchell Taebel, a known sovereign citizen with a long-troubled history, was arrested after leading law enforcement on a high-speed chase (Pohl, 2018) . Two persons were severely injured, during the chase, when his vehicle slammed in to theirs. In a press conference, and on a number of other occasions, he stated, that the officers involved should have been killed and that he had the right to kill them under specific sections of the Uniform Crime Code (Pohl, 2018) . His actions are in line with many sovereign citizens who often cite the U.S. Constitution or common law statues that they interpret as supporting their antigovernment and anti-authority agendas.

This article sought to provide an overview of sovereign citizens, summarize the empirical research about the movement and to explore the threat they pose to law enforcement. To date, there are relatively few studies of sovereign citizens. This may be due to the fact that very few In addition, sovereign citizens are not a monothetic or ideologically pure group. Their ideology oftentimes overlaps with other groups including militias, antigovernment groups, and patriot/white supremacy groups. Others with overlapping philosophies include the Black Panther party, scientology, anti-vaccination, dooms day preppers, and other movements. This complicates counterterrorism efforts that have traditionally "focus[ed] on leadership decapitation and targeting organizational logistics and finances…" (Hoffman & Ware, 2020, para.30) .

Sovereign citizens, like some other groups, are decentralized and have "…no identifiable leaders, no existing organization and no infrastructure to disrupt" (Hoffman & Ware, 2020, para.30 ) thus making identification and prevention a formidable task. Further complicating matters, is the lack of governmental authority to clarify issues of operational definition and ideology. Without such guidance, accurate accounting, especially among those without access to classified intelligence, becomes a greater challenge.

Studies concerning the sovereign citizen movement thus far have largely focused on legal matters, mental health, radicalization, and postdiction of targeted violence. Emerging evidence suggests that most sovereign citizens are not delusional or mentally ill. Their behavior defies easy diagnostic categorization and requires further study. Their beliefs, though atypical in nature, are largely not indicative of disordered thought. Some sovereign citizens are motivated to commit violence for reasons that have yet to be fully explored. Rahman, Meloy, and Bauer (2019) have applied the concept of extreme overvalued belief to lone-actor terrorism and individual acts of targeted violence. Whether sovereign citizen ideology should be understood as an extreme, overvalued belief, will require more in-depth study. Understanding what motivates sovereign citizens could reveal important insights for developing prevention strategies.

Exploring the movement's threat to law enforcement involved a collection of 94 instances in which sovereign citizens did harm police officers, attempted to harm them or threatened to do so.

Violence aimed at police often began with routine traffic stops, where sovereigns were accused of violating basic traffic laws or had outstanding warrants. These stops were sometimes made worse by sovereigns fleeing the scene, thus escalating the situation. The findings of this research are consistent with other research indicating that most deadly far-right attacks on law enforcement are triggered by routine traffic stops (Grenewald, et al., 2016) .

Sovereign citizen deadly violence against LEOs also occurred during ambushes. Though traffic stops are a large danger to LEOs, and often trigger sovereign citizen violence, the danger of an ambush is both real and deadly. The targeted attacks on LEOs, both those that were carried out successfully and those that were attempted but thwarted, highlight the predatory capacity of the sovereign citizen movement.

Invariably, the descriptive nature of this analysis has limitations. The sample size, involving attacks and threats on LEOs, is too small to draw satisfactory conclusions. In addition, the data were collected from media-based reports, which are subject to errors and can lack completeness (Huff-Corzine, McCutcheon, & Corzine, 2014) . Without access to classified government data, media access, of this type, is often the only available information. Relatedly, despite a thorough and ongoing search, cases may have been missed. There may also have been cases that other researchers would have categorized differently. As mentioned above, some individuals were espousing sovereign citizen ideology but could have also been labeled as tax protestors or militias members, among others. Other researchers might have omitted those seemingly blended, This research took a conservative approach and only included cases where definitive sovereign ties were clear. An example of a case that was omitted was Martin Winters, leader of a doomsday survivalist group. Mr. Winters was arrested for illegally obtaining assault rifles and building bombs (Sullivan & Ryan, 2014) . The FBI considered him an "extremely dangerous"

individual who plotted to kill government agents, should they invade his property (Masferrer, 2014) . One journalist labeled him a sovereign citizen but since his connection to the movement could not be independently verified, a decision was made to eliminate him from this sample of cases.

Despite its drawbacks, a descriptive approach can be valuable, especially given the limited empirical information available concerning sovereign citizens. Even more limited is the information available to guide law enforcement agencies, who do interact directly with sovereign citizens, in the course of routine police work (Grenewald, et al., 2016; Smith, 2019) . Given LEO's regular contact with sovereign citizens, and the danger posed by sovereigns, the lack of mandated training programs, on this movement, is concerning (Smith, 2019) . Some law enforcement agencies offer optional training. Such training should not be optional but instead mandatory and universal. Past training has likely saved the lives of many LEOs and could prevent future tragedies. Beyond training alone, additional measures are needed to combat the danger posed by the sovereign citizen movement. This danger is not limited to law enforcement but extends to public officials, and to society at large. 

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