United States v. Christensen

• Court: District Court, D. Nevada
• Decided: September 17, 2025
• Docket: 2:22-cv-00605
• Status: Unknown

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA

3 4 United States of America, Case No. 2:22-cv-00605-JAD-BNW

5 Plaintiff v. 6 Order Cody J. Christensen, et al., 7 ECF Nos. 59 & 60 Defendants 8

10 This was an action by the United States government to reduce to judgment trust- 11 fund recovery penalties and federal income-tax assessments owed by defendant Cody 12 Christensen and to foreclose upon the liens on his property to satisfy his tax liability. 13 This case ended more than a year ago when the court granted summary judgment in favor 14 of the government and against Christensen.1 He later appealed, but the Ninth Circuit 15 Court of Appeals dismissed that appeal for lack of jurisdiction.2 This case remains 16 closed. 17 Christensen has now filed something he’s titled a “Judicial Notice and 18 Constitutional Challenge.”3 Drawing from typical “sovereign citizen,” tax-avoidance 19 ideology, this filing states that it is “a non-negotiable commercial instrument” that 20 1 See generally ECF No. 49. 21 2 ECF No. 57. 22 3 ECF Nos. 59, 60. 1] “serves as a lawful and constitutional challenge to this Court’s authority to proceed 2|| without first proving on the record” a list of “elements.” It concludes by warning that, 3} “[u]nrebutted, this notice shall stand as law and judgment in both private and public record,” and that “[f]ailure to respond constitutes” both an “admission that no jurisdiction 5] exists” and a violation of this court’s “oath of office and fiduciary duty.”° Notions like 6] these are based in sovereign citizen ideology, and the courts have uniformly rejected 7|| them as frivolous nonsense.° 8 IT IS HEREBY ORDERED that: 9 e This court will take no action in response to Christensen’s “Judicial Notice and Constitutional Challenge.” 10 e That filing has no legal effect on this court. 11 e Any future filings in this case, other than a properly supported and timely 12 motion under Federal Rule of Civil Procedure 60, will be struck without further advance notice. 13 14 USS. DistrtetJudge Jennifer A. Dorsey September 17, 2025

+ ECF No. 59 at 1 (cleaned up). 1 Of Td. at 2. 17||° See United States v. Ward, 182 F.3d 930 (9th Cir. 1999) (unpublished); see also United States v. Mundt, 29 F.3d 233, 237 (6th Cir. 1994) (noting that sovereign-citizen theories 18]| attempting to avoid paying taxes are “silly” or “frivolous”’); Bey v. State of Indiana, 847 F.3d 559, 559-61 (7th Cir. 2017) (calling a plaintiff's attempt to avoid taxation as a 19]| sovereign citizen “frivolous” and noting that “he was lucky to be spared sanctions for filing such a suit”); United States v. Benabe, 654 F.3d 753, 767 (7th Cir. 2011) (stating that sovereign-citizen “theories should be rejected summarily, however they are presented”); United States v. Studley, 783 F.2d 934, 937 n. 3 (9th Cir. 1986) (noting that 21||sovereign-citizen tax arguments have “been consistently and thoroughly rejected by every branch of the government for decades” and that “such utterly meritless arguments [are] 22||now the basis for serious sanctions imposed on civil litigants who raise them’). 23