Courvelle v. McCormick

IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF ARKANSAS
HOT SPRINGS DIVISION
SHERREL JEAN
COURVELLE 	PLAINTIFF
v. 	Case No. 6:24-cv-06088
MIKE MCCORMICK,
Sheriff of Garland County,
Arkansas 	DEFENDANT
ORDER
Before the Court is the Report and Recommendation (“R&R”) filed October 31, 2024, by
the Honorable Barry A. Bryant, United States Magistrate Judge for the Western District of
Arkansas. 	(ECF No. 19). 	Judge Bryant recommends that Plaintiff Sherrel Jean Courvelle’s
(“Plaintiff”) Habeas Corpus Petition pursuant to 28 U.S.C. § 2254 be dismissed without
prejudice for failure to exhaust available state remedies.
Plaintiff has filed objections to Judge Bryant’s R&R, subscribing to what is commonly
known as “sovereign citizen” ideology—despite her protests otherwise.1 	(ECF No. 24). 	In
support of her perceived status and immunity from the laws of this country, she has filed thirteen
(13) pages of objections and thirty-three (33) pages of supporting documents. (ECF No. 24; ECF
No. 24-1; ECF No. 24-2). 	These documents are largely incomprehensible and present no
specific objections to Judge Bryant’s R&R. Further, the Eighth Circuit has long held that claims
and arguments based on sovereign citizen ideology are inherently frivolous and are a waste of
1Plaintiff states “Comes Now, Sherrel Jean Courvelle, the living woman, an Arkansas State Citizen, standing
on Land and Soil Jurisdiction. I am NOT a U.S. Citizen, I am NOT a citizen of the United States, I am Not a
CORPORATE FRANCHISE.” (ECF No. 24, at 2). Further, she believes the United States government is a
corporation. (ECF No. 24, at 9). These are commonly used sovereign citizen terms and beliefs. See generally
Federal Bureau of Investigation Domestic Terrorism Unit, Sovereign Citizens: An Introduction for Law
Enforcement, available at https://info.publicintelligence.net/FBI-SovereignCitizens.pdf (last accessed Nov. 21,
2024).
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judicial resources. See United States v. Jagim, 978 F.2d 1032, 1036 (8th Cir. 1992) (Ruling that
sovereign citizen claims in the case were without merits, patently frivolous, and should be
rejected without wasting anymore of the Court’s resources on their discussion); see also Engel v.
Corizon, No. 4:20-CV-1744-HEA, 2021 WL 1105351, at *3 (E.D. 	Mo. Mar. 23, 2021)
(“Arguments based upon sovereign citizen ideology have been summarily rejected as frivolous
and irrational in this Circuit and in other federal courts around the nation”).
Upon review, finding no clear error on the face of the record and that Judge Bryant’s
reasoning is sound, the Court adopts the Report and Recommendation (ECF No. 19) in toto.
Accordingly, Plaintiff’s Habeas Corpus Petition pursuant to 28 U.S.C. § 2254 is hereby
DISMISSED WITHOUT PREJUDICE for failure to exhaust available state remedies.
IT IS SO ORDERED, this 10th day of January, 2025.
/s/ Susan O. Hickey
Susan O. Hickey
Chief United States District Judge
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