United States v. Ulloa, 511 F. App'x 105 (2d Cir. 2013). · Go Syfert
United States v. Ulloa, 511 F. App'x 105 (2d Cir. 2013). Cases Citing This Book View Copy Cite
77 citation events (77 in the last 25 years) across 25 distinct courts.
Strongest positive: James Alexander Ray v. Leslie Cooley Dismukes, et al. (ncwd, 2026-04-20)
Treatment trajectory · 2013 → 2026 · click a year to view as-of
2013 2019 2026
Top citers, strongest first. 25 distinct citers. How cited ↗
discussed Cited as authority (quoted) James Alexander Ray v. Leslie Cooley Dismukes, et al.
W.D.N.C. · 2026 · quote attribution · 1 verbatim quote · confidence low
sovereign citizens are a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior
examined Cited as authority (quoted) Balash-Ioannidou v. Contour Mortgage Corporation
E.D.N.Y · 2022 · signal: see · quote attribution · 1 verbatim quote · confidence high
overeign citizens are a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior; the fbi has labeled the sovereign citizens a domestic terrorist group.
discussed Cited as authority (quoted) Pondexter v. Murrieta
D. Ariz. · 2021 · quote attribution · 1 verbatim quote · confidence low
sovereign citizens are 5 a loosely affiliated group who believe that the state and federal governments lack 6 constitutional legitimacy and therefore have no authority to regulate their behavior
discussed Cited as authority (quoted) Gayles El v. State of North Carolina Inc
W.D.N.C. · 2020 · quote attribution · 1 verbatim quote · confidence low
sovereign citizens are a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior
discussed Cited as authority (rule) Decatus v. the City
S.D.N.Y. · 2024 · confidence medium
Sovereign Citizen Claims Plaintiff’s belief that she is entitled to relief appears to be based on “sovereign citizen” claims.3 As the Second Circuit has explained, “sovereign citizens are a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior.” United States v. Ulloa, 511 F. App’x 105, n.1 (2d Cir. 2013); see also United States v. McLaughlin, 949 F.3d 780, 781 (2d Cir. 2019) (cleaned up) (noting that “so-called ‘Sovereign Citizens’ seek to clog the wheels of justic…
discussed Cited as authority (rule) Milan of the Family Hall v. Stack
N.D.N.Y. · 2023 · confidence medium
Plaintiffs appear to suggest that they are sovereign citizens—meaning “that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior,” United States v. Ulloa, 511 F. App’x 105, 107 (2d Cir. 2013).
discussed Cited as authority (rule) In Re: Cameron
D. Conn. · 2023 · confidence medium
Plaintiff's submissions and the allegations contained therein are characteristic of claims by “sovereign citizens.” For example, Plaintiff refers to himself via a “business/legal name,” Pet. ¶ 4 n.1, and claims that “he is not bound by any institution formed by his fellow men without his consent.” The Second Circuit has described sovereign citizens as “a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior.” United States v. Ulloa, 511 F. App'x 105, 107 (2d Cir. 201…
discussed Cited as authority (rule) Jeannite v. Wright
D. Mass. · 2023 · confidence medium
Jones-El v. South Carolina, No. 5:13-cv- 01851, 2014 WL 958302 , at *8 (rejecting claim based on status as Moorish American and relying on the Treaty of Peace and 8 The pleadings submitted by Jeannite are replete with Moorish sovereign citizen movement jargon. “[T]he sovereign citizens are a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior.” United States v. Ulloa, 511 F. App’x 105, 107 (2d Cir. 2013) (summary order).
discussed Cited as authority (rule) Shahadi El v. Suffolk County Police Department
E.D.N.Y · 2023 · confidence medium
B. 3.) [Main text continued on next page.] have no authority to regulate their behavior.” United States v. Ulloa, 511 F. App’x 105, 107 (2d Cir. 2013) (summary order). 4 There are no attachments, fee schedules or otherwise, included with the Complaint. 5 No attachments were filed with the Court when Plaintiff originally filed the Complaint on May 4, 2021 or when it was resubmitted on December 28, 2022.
cited Cited as authority (rule) Brown Bey v. State of New York (Inc)
E.D.N.Y · 2022 · confidence medium
Aug. 25, 2022) (quoting United States v. Ulloa, 511 F. App’x 105, 107 (2d Cir. 2013)).
discussed Cited as authority (rule) In Re :Charlesetta O'Neal
E.D.N.Y · 2022 · confidence medium
As the Second Circuit has explained, “[t]he sovereign citizens are a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior.” United States v. Ulloa, 511 F. App’x 105, n.1 (2d Cir. 2013).
discussed Cited as authority (rule) Kevin James Walker Estate v. Wuchte
E.D.N.Y · 2022 · confidence medium
“The sovereign citizens are a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior.” United States v. Ulloa, 511 F. App'x 105, 107 (2d Cir. 2013) (summary order).
discussed Cited as authority (rule) Patino Mancia v. Annucci
W.D.N.Y. · 2022 · confidence medium
Plaintiff subsequently submitted three motions to proceed in forma pauperis (Dkt. 4; Dkt. 6; Dkt. 9) with supporting documentation (Dkt. 7; Dkt. 8). 4 The sovereign citizen movement is “a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior.” United States v. Ulloa, 511 F. App’x 105, 107 (2d Cir. 2013) (summary order); see also, Charles E.
discussed Cited as authority (rule) Aran v. The Department of Treasury
E.D.N.Y · 2022 · confidence medium
As the Second Circuit has explained, “[t]he sovereign citizens are a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior.” United States v. Ulloa, 511 F. App'x 105, n. 1 (2d Cir. 2013).
discussed Cited as authority (rule) Clay v. Riordan
W.D.N.Y. · 2020 · confidence medium
Plaintiff signed the complaint and many of the papers attached to it with 1 “The sovereign citizens are a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior.” United States v. Ulloa, 511 F. App’x 105, 107 (2d Cir. 2013) (summary order). references to the Uniform Commercial Code, to trusts in his name, and to his identity as “a natural flesh and blood man,” all indicia of sovereign-citizen filings.
cited Cited "see" Johnathon Hulley v. Carrington Mortgage Services, LLC.
W.D. Mich. · 2025 · signal: see · confidence high
See United States v. Ulloa, 511 F. App’x 105 , 106 n.1 (2d Cir. 2013); Waters v. Madson, 921 F.3d 725 , 732 n.4 (8th Cir. 2019).
cited Cited "see" Davis v. Heaton
W.D. Mich. · 2025 · signal: see · confidence high
See United States v. Ulloa, 511 F. App’x 105 , 106 n.1 (2d Cir. 2013); Waters v. Madson, 921 F.3d 725 , 732 n.4 (8th Cir. 2019).
discussed Cited "see" Sposato v. Carey
N.D.N.Y. · 2024 · signal: see · confidence high
See United States v. Ulloa, 511 Fed.
cited Cited "see" Bullock El-Bey v. North Carolina Department of Public Safety
W.D.N.C. · 2023 · signal: see · confidence high
See United States v. Ulloa, 511 F. App’x 105 , 106 n.1 (2d Cir. 2013); Waters v. Madson, 921 F.3d 725 , 732 n.4 (8th Cir. 2019).
cited Cited "see" Com. v. Spence, L.
Pa. Super. Ct. · 2021 · signal: see · confidence high
See United States v. Ulloa, 511 Fed.Appx. 105, 108 (2d Cir. 2013).
cited Cited "see" Wright v. United States
W.D.N.C. · 2020 · signal: see · confidence high
See United States v. Ulloa, 511 Fed.
discussed Cited "see, e.g." Cotner v. Tulsa Mayor/ City Police & Courts
W.D. Okla. · 2024 · signal: see also · confidence low
These theories should be rejected summarily, however they are presented.” Id. (emphasis added) (quoting United States v. Benabe, 654 F.3d 753, 767 (7th Cir. 2011)); see also Lonsdale v. United States, 919 F.2d 1440, 1448 (10th Cir. 1990) (rejecting similar arguments in the taxation context). “[A]n individual’s belief that her status as a ‘sovereign citizen’ puts her 3 The Court uses CM/ECF page numbering across the top of filings. 4 Cf. United States v. Ulloa, 511 F. App’x 105 , 106 n.1 (2d Cir. 2013) (unpublished) (“The sovereign citizens are a loosely affiliated group who belie…
discussed Cited "see, e.g." Young v. Reis
D. Conn. · 2023 · signal: see, e.g. · confidence low
See, e.g., United States v. Ulloa, 511 F. App’x 105 , 106 n.1 (2d Cir. 2013) (summary order) (“The sovereign citizens are a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior.”); Gravatt v. United States, 100 Fed.
discussed Cited "see, e.g." Barnhart v. Dilinger
N.D. Ohio · 2020 · signal: see, e.g. · confidence low
See, e.g., United States v. Ulloa, 511 F. App'x 105 , 107 n.1 (2d Cir. 2013) (“The sovereign citizens are a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior.
discussed Cited "see, e.g." Cooper v. The City of Chicago
N.D. Ill. · 2018 · signal: see also · confidence low
See also United States v. Ulloa, 511 F. App'x 105 , 106 n.1 (2d Cir. 2013) (noting that the FBI has described sovereign citizens as a "domestic terrorist group").
Retrieving the full opinion text from the archive…
UNITED STATES of America, Appellee,
v.
Richard Enrique ULLOA, Defendant-Appellant
11-5368.
Court of Appeals for the Second Circuit.
Feb 14, 2013.
511 F. App'x 105
Molly Corbett, Federal Public Defender Office, Albany, NY, for Lisa A. Peebles, Acting Federal Public Defender, for Appellant., Rajit S. Dosanjh (Richard D. Beiliss, on the brief), for Richard S. Hartunian, United States Attorney for the Northern District of New York, Syracuse, NY, for Ap-pellees.
Jacobs, Kearse, Carney.
Cited by 64 opinions  |  Unpublished
3 passages pin-cited by 4 cases
Pinpoint authority: #23,023 of 633,719
Citer courts: D. Arizona (1) · W.D. North Carolina (1) · E.D. New York (1)

SUMMARY ORDER

Defendant-Appellant Richard Ulloa appeals from a conviction and sentence imposed by the United States District Court for the Northern District of New York (McAvoy, Ulloa, an adherent of the “sovereign citizens” movement, [1] conducted[*107] a scheme chiefly involving baseless liens and other fraudulent filings and documents demanding money from his numerous victims. The jury convicted Ulloa of seven counts of mail fraud under 18 U.S.C. §§ 1341 and 1349. He was sentenced to 60 months’ imprisonment on each count, to run concurrently. We assume the parties’ familiarity with the underlying facts, the procedural history, and the issues presented for review.

1. Ulloa argues that the government lacked sufficient evidence of his intent to deceive. A defendant challenging the sufficiency of the evidence “bears a heavy burden.” United States v. Caracappa, 614 F.3d 30, 43 (2d Cir.2010). We “must credit every inference that could have been drawn in the government’s favor, and affirm the conviction so long as, from the inferences reasonably drawn, the jury might fairly have concluded guilt beyond a reasonable doubt.” United States v. Rei-fler, 446 F.3d 65, 94 (2d Cir.2006) (internal citations omitted).

Conviction under the mail fraud statute, 18 U.S.C. § 1341, requires the government to prove “(1) a scheme to defraud victims of (2) money or property, through the (3) use of the mails.” United States v. Walker, 191 F.3d 326, 334 (2d Cir.1999). Ulloa contends that his conduct was “open and frank” rather than deceptive, and that “[h]e believed that he had. been wronged and candidly sought recompense for the injuries he suffered,” and thus lacked the requisite intent. Appellant Br. 18. But the government put forth several examples of Ulloa’s bad intent, including a threat (acted upon) to harass a police officer, made during a routine traffic stop, a statement to FBI agents that his intent was revenge, and emails to credit ratings agencies making them aware of the liens.

2. Ulloa contends that the government was required to prove that the person deceived by the scheme was the same person harmed by the scheme, and that the requisite showing was not made because his victims were well aware that the liens and other documents were fraudulent. This argument misconstrues the elements of the offense. With respect to the scheme-to-defraud element, “the government is not required to show that the intended victim was actually defrauded”; it is sufficient to show “that the defendant ] contemplated some actual harm or injury.” United States v. Wallach, 935 F.2d 445, 461 (2d Cir.1991). Because the evidence strongly suggests that Ulloa contemplated actual harm or injury, his claim is meritless.

3. Ulloa challenges the procedural reasonableness of his sentence. The district court decided that a calculation of the victims’ actual loss (roughly $63,000) was a more appropriate measure than the intended loss (approximately $6.75 billion). The result was an offense level of 16, and the Guidelines range was 21 to 27 months. [2] The court, however, determined that offense level 16 was inadequate given the extent of the misconduct and increased the offense level to 25, resulting in a Guidelines range of 57 to 71 months. The court then sentenced Ulloa to 60 months’ imprisonment on each count, to be served concurrently.

Ulloa challenges this sentence on the ground that the court’s statement of rea[*108] sons was based on Ulloa’s potential to re-offend, not his actual conduct. However, at sentencing and in its statement of reasons, the district court did not intimate that its upward departure was based on Ulloa’s likely recidivism, but rather on the fact that the offense level substantially understated the seriousness of the offense. This was not error. See U.S.S.G. § 2B1.1 cmt. n. 19(A) (2012).

Ulloa also contends that the court’s sentence punished him for his involvement in a political movement and therefore infringed his First Amendment rights. However, the First Amendment “ ‘does not erect a per se barrier’” to a sentencing court’s admission of evidence regarding the defendant’s beliefs, which may be relevant, e.g., to show motive, to examine an aggravating factor, to illustrate future dangerousness, or to rebut mitigating evidence. United States v. Kane, 452 F.3d 140, 142-43 (2d Cir.2006) (per curiam) (quoting Dawson v. Delaware, 503 U.S. 159, 165, 112 S.Ct. 1093, 117 L.Ed.2d 309 (1992)). Ulloa’s involvement in the sovereign citizens was considered to show motive (his desire to punish anyone who crossed him) and to rebut mitigating evidence (Ulloa’s claim that he was delusional), both permissible considerations.

For the foregoing reasons, and finding no merit in Ulloa’s other arguments, we hereby AFFIRM the judgment of the district court.

1

. The sovereign citizens are a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior. The FBI has labeled the sovereign citizens a domestic terrorist group. See “Sovereign Citizens A Growing Domestic Threat to Law Enforcement,” FBI Law En[*107] forcement Bulletin (Sept. 2011), http://www. fbi.gov/stats-services/publications/law-enforcement-bulletin/september-2011/ sovereign-citizens.

2

. Had the court used the intended loss figure, Ulloa’s Guidelines range would have been 292 to 365 months.