At page 107 Analyzing elements of mail fraud conviction49 citing casesa scheme chiefly involving baseless liens and other fraudulent filings and documents demanding money from his numerous victims. The jury convicted Ulloa of…
- Decatus v. City, No. 1:24-cv-02224 (S.D.N.Y. May 13, 2024).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 sta…
- Milan of the Fam. Hall v. Stack, No. 8:23-cv-00014 (N.D.N.Y. Nov. 17, 2023).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…
- In re Cameron, No. 3:22-cv-01216 (D. Conn. May 17, 2023).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…
- Jeannite v. Wright, No. 1:22-cv-11060 (D. Mass. May 1, 2023).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 cit…
- Shahadi El v. Suffolk Cnty. Police Dep't, No. 2:21-cv-02500 (E.D.N.Y. Apr. 12, 2023).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 t…
- Brown Bey v. State of New York (Inc), No. 1:22-cv-03408 (E.D.N.Y. Oct. 28, 2022).Aug. 25, 2022) (quoting United States v. Ulloa, 511 F. App’x 105, 107 (2d Cir. 2013)).
- In re Charlesetta O'Neal, No. 1:20-cv-04060 (E.D.N.Y. Aug. 31, 2022).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.” Un…
- Kevin James Walker Est. v. Wuchte, No. 2:22-cv-01532 (E.D.N.Y. Aug. 25, 2022).“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,…
- Patino Mancia v. Annucci, No. 6:21-cv-06675 (W.D.N.Y. May 16, 2022).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…
- Aran v. Dep't of Treasury, No. 1:21-cv-04748 (E.D.N.Y. Feb. 8, 2022).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.” Un…
Show 39 more citing cases
- Clay v. Riordan, No. 1:18-cv-00933 (W.D.N.Y. July 10, 2020).Plaintiff signed the complaint and many of the papers attached to it with 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. 1…
- Sposato v. Carey, No. 5:23-cv-00364, 2024 WL 637423 (N.D.N.Y. Feb. 15, 2024).See United States v. Ulloa, 511 Fed. Appx. 105 , 107 n.1 (2d Cir. 2013)(describing “sovereign citizens” as “a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no…
- Young v. Reis, No. 3:22-cv-00985 (D. Conn. May 18, 2023).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 ther…
- Johnson v. Raffy's Café I, LLC, 163 A.3d 672 (Conn. App. Ct. 2017).published
- Sterling v. 1279 St. Johns Place, LLC (In re Sterling), 565 B.R. 258 (S.D.N.Y. 2017).published
- Johnson-Bey v. Arkansas Dep't of Corr., No. 4:20-cv-00827 (E.D. Ark. Oct. 14, 2020).
- Miller v. Semple, No. 3:18-cv-01769 (D. Conn. Nov. 25, 2019).
- Jersey: Osorio v. Gallo, No. 3:19-cv-00151 (D. Conn. Mar. 31, 2020).
- Gonzalez-Torres v. Roy, No. 3:19-cv-01139 (D. Conn. Oct. 9, 2020).
- Price v. Lakeview Loan Servicing, LLC, No. 2:19-cv-00655, 2021 WL 1610097 (M.D. Fla. Apr. 26, 2021).
- King/Morocco v. Mercedes Benz of New Orleans, No. 2:18-cv-08964 (E.D. La. July 30, 2019).
- Gallman v. Barr, No. 5:19-cv-00171 (W.D.N.C. July 17, 2020).
- Leaks v. State of NC, No. 3:22-cv-00108 (W.D.N.C. Feb. 28, 2023).
- Elmore v. Mecklenburg Cnty. Courthouse, No. 3:23-cv-00036 (W.D.N.C. Apr. 18, 2023).
- Jeremy Lamond Henderson v. Haynes, No. 3:23-cv-00583 (W.D.N.C. Feb. 5, 2024).
- James v. D'Amore, No. 2:22-cv-01120 (E.D.N.Y. Feb. 1, 2024).
- Wilson v. Nelnet Inc., No. 1:23-cv-08305 (E.D.N.Y. Apr. 29, 2024).
- Wilson v. Blackley, No. 1:23-cv-07968 (E.D.N.Y. Apr. 29, 2024).
- Junior-Tony Dieujuste v. Sin, 731 F. Supp. 3d 440 (E.D.N.Y. 2024).published
- Stevens Cnty. v. Each & Every Lot, No. 39350-0 (Wash. Ct. App. Aug. 15, 2024).unpublished
- Cascone v. Williams, No. 8:24-cv-04665 (D.S.C. Oct. 25, 2024).
- In re Carolyn Brantley, No. 9:24-cv-03603 (D.S.C. Feb. 5, 2025).
- Barksdale v. Cnty. of Grayson, No. 7:25-cv-00196 (W.D. Va. Apr. 21, 2025).
- Arnold v. Santander Consum. USA, No. 3:24-cv-01125, 2025 WL 1358546 (D. Conn. May 9, 2025).
- Fuce v. Fuce, No. 3:25-cv-03053 (D.S.C. Apr. 23, 2025).
- Lodges in West Yakima, LLC v. David Perez Ortiz, No. 40087-5 (Wash. Ct. App. June 3, 2025).unpublished
- Bey v. Carillo, No. 1:25-cv-02099 (S.D.N.Y. June 10, 2025).
- Murphy v. PHH Mortg. Servicers, No. 3:23-cv-01552 (D. Conn. June 18, 2025).
- Gittens v. Lennard Johnson, No. 1:22-cv-02704 (D. Md. July 14, 2025).
- Page v. Fifth Third Bank, NA, No. 1:25-cv-00405 (N.D. Ind. July 28, 2025).
- Scott v. Westlake Fin., LLC, No. 3:25-cv-00004 (W.D.N.C. Sept. 25, 2025).
- Johnson v. Town of Weare, N H, 2013 DNH 140 (D.N.H. 2013).published
- Strong, No. 6:25-cv-08691 (D.S.C. Oct. 8, 2025).
- DuBose, No. 3:26-cv-00470 (D. Conn. May 5, 2026).
- State of South Carolina v. Bralyn Jackson, No. 6:26-cv-01209 (D.S.C. Mar. 24, 2026).
- Wanda S. Henderson v. Easley Police Dep't, No. 6:26-cv-01444 (D.S.C. Apr. 21, 2026).
- Kelly, No. 1:26-cv-04105 (S.D.N.Y. June 17, 2026).
- Groves, No. 7:26-cv-00495 (W.D. Va. Sept. 21, 2026).
- Booth, No. 7:26-cv-00537 (W.D. Va. Sept. 21, 2026).
At page 108 Analyzing sentencing factors and first amendment rights8 citing cases“a loosely affiliated group who believe that the state and federal governments lack constitutional legitimacy and therefore have no authority to regulate their behavior.”
- Ray, No. 1:26-cv-00090 (W.D.N.C. Apr. 20, 2026).(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)
- Balash-Ioannidou v. Contour Mortg. Corp., No. 1:22-cv-04506, 2022 WL 3358082 (E.D.N.Y. Aug. 15, 2022).([S]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…)
- Pondexter v. Murrieta, No. 2:20-cv-02124 (D. Ariz. Jan. 20, 2021).(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)
- Joiner v. Hooks, No. 1:20-cv-00132 (W.D.N.C. Dec. 1, 2020).(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)
- Gayles El v. State of North Carolina Inc, No. 1:20-cv-00125 (W.D.N.C. Oct. 13, 2020).(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)
- Cooper v. City of Chicago, No. 1:16-cv-03519 (N.D. Ill. Mar. 20, 2018).Hairston v. Warden, 597 F.2d 604 , 607-08 (7th Cir. 1979); U.S. v. Montgomery, 390 F.3d 1013 (7th Cir. 2004); U.S. v. Wray, 664 F. App’x 160, 162 (3d Cir. 2016); Ulloa, 511 F. App’x at 108; U.S. v. Bell, 585 F. App’x 552, 553 (9th Cir. 201…
- Sposato v. Carey, No. 5:23-cv-00364, 2024 WL 637423 (N.D.N.Y. Feb. 15, 2024).(describing “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)
- Com. v. Spence, L., No. 87 MDA 2021 (Pa. Super. Ct. Aug. 30, 2021).unpublishedSee United States v. Ulloa, 511 Fed.Appx. 105, 108 (2d Cir. 2013).
Other citing cases
- Shawna-Grace Sandoval v. Travis Credit Union, No. 2:26-cv-02309 (E.D. Cal. Sept. 22, 2026).
- Warden, No. 1:26-cv-05278 (E.D. Cal. Aug. 10, 2026).
- Shawna-Grace Sandoval v. Travis Credit Union, No. 2:26-cv-02309 (E.D. Cal. Aug. 4, 2026).
- Lux Veritas E.E. Trust & Nicholas David Paul Sedlock v. Wayne Serv., Inc., No. 2:26-cv-11960 (E.D. Mich. July 8, 2026).
- Hulley, No. 1:25-cv-00626 (W.D. Mich. Dec. 29, 2025).
- Davis v. Heaton, No. 1:24-cv-01050 (W.D. Mich. July 30, 2025).
- Bullock El-Bey v. North Carolina Dep't of Pub. Saf., No. 5:21-cv-00084, 2023 WL 1073721 (W.D.N.C. Jan. 27, 2023).
- Bey v. Furman, No. 1:21-cv-04090 (E.D.N.Y. Aug. 23, 2021).
- Wright v. United States, No. 1:19-cv-00146 (W.D.N.C. Apr. 6, 2020).
- Ngambo, No. 7:26-cv-06060 (S.D.N.Y. Aug. 12, 2026).
Show 3 more citing cases
- Cotner v. Tulsa Mayor/ City Police & Courts, No. 5:23-cv-00730 (W.D. Okla. Feb. 26, 2024).
- Barnhart v. Dilinger, No. 3:16-cv-02597 (N.D. Ohio Nov. 30, 2020).
- Cooper v. City of Chicago, No. 1:16-cv-03519, 2018 WL 3970141 (N.D. Ill. Aug. 20, 2018).
v.
Richard Enrique ULLOA, Defendant-Appellant
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.
. 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.
. Had the court used the intended loss figure, Ulloa’s Guidelines range would have been 292 to 365 months.