United States v. Michael Bentley, III

CourtCourt of Appeals for the Sixth Circuit
DecidedDecember 16, 2025
Docket24-5433
StatusUnpublished

This text of United States v. Michael Bentley, III (United States v. Michael Bentley, III) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Michael Bentley, III, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0580n.06

No. 24-5433

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Dec 16, 2025 KELLY L. STEPHENS, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE EASTERN ) DISTRICT OF TENNESSEE MICHAEL BENTLEY III, ) Defendant-Appellant. ) OPINION )

Before: CLAY, KETHLEDGE, and LARSEN, Circuit Judges.

CLAY, Circuit Judge. Defendant Michael Bentley III appeals from his sentence for

Conspiracy to Distribute 50 Grams or More of Methamphetamine (Actual) under 21 U.S.C.

§§ 846, 841(a)(1) and 841(b)(1)(A), Attempt to Possess with Intent to Distribute 50 Grams or

More of Methamphetamine (Actual) under the same statutes, and Using, Carrying, and

Brandishing a Firearm During and in Relation to a Drug Trafficking Offense under 18 U.S.C.

§ 924(c)(1)(A)(ii). For the reasons set forth below, we AFFIRM Bentley’s sentence.

I. BACKGROUND

A. Factual Background

In 2020, law enforcement was investigating a drug trafficking organization supplying

methamphetamine and other drugs into the Eastern District of Tennessee. As part of that

investigation, agents monitored packages sent to the Eastern District of Tennessee from a certain

area in California. On February 28, 2022, agents intercepted a suspicious package from California

bound for Bentley’s grandparents’ home. They seized the package and found that it contained No. 24-5433, United States v. Bentley

nearly a kilogram of highly pure methamphetamine. Agents replaced the drugs with fake

methamphetamine and then sent the package along to its intended destination. They surveilled

Bentley’s grandparents’ house, and when they observed Bentley there with the package, they

attempted to arrest him. He fled, pulling a gun from his waistband in the process, and holding it

in the direction of the law enforcement agents. Bentley insists that he did not intentionally point

the gun at anyone and that at most he swept it in their general direction. The agents heard a gunshot

and returned fire as they continued to observe Bentley running away with the gun pointed in their

direction. Ultimately, the agents apprehended Bentley, and he admitted to trafficking

methamphetamine.

B. Procedural Background

A Second Superseding Indictment charged Bentley with Conspiracy to Distribute 50

Grams or More of Methamphetamine under 21 U.S.C. §§ 846, 841(a), and 841(b)(1)(A), Attempt

to Possess with Intent to Distribute 50 Grams or More of Methamphetamine under the same

provisions, and Using, Carrying, and Brandishing a Firearm During and in Relation to a Drug

Trafficking Crime under 18 U.S.C. § 924(c)(1)(A)(ii). Bentley refused to enter a plea, and the

district court granted the government’s motion to enter a plea of not guilty on his behalf.

Throughout the court proceedings, Bentley asserted in multiple filings and hearings that he

was subject to neither the criminal laws of the United States nor the jurisdiction of its courts and

that his case should be settled commercially. In at least one instance, the district court noted that

a submission by Bentley was reminiscent of “the sovereign citizen movement” and “warned

[Bentley] that any future filings premised on sovereign citizen lore . . . [would] be summarily

denied.” Order, R. 78, PageID #252–53. Bentley took issue with the district court’s reference to

-2- No. 24-5433, United States v. Bentley

the sovereign citizen movement because it carried a negative connotation, but he continued to raise

the same substantive ideas. A jury found Bentley guilty of all counts.

Bentley continued his jurisdictional protest through sentencing. In his sentencing

memorandum, he stated that the judicial power of the United States is vested in the Supreme Court,

the common law is the supreme law of the land, and the district court is an Article I court with

authority to deal only with commerce and therefore lacking jurisdiction to adjudicate his case. He

requested a sentence of time served.

At Bentley’s sentencing hearing, the district court acknowledged the advisory guidelines

custodial sentence range. For each of the drug trafficking counts, the guidelines range was 210 to

262 months with a 10-year mandatory minimum. The firearm count carried a statutory range of

seven years’ to life imprisonment. The total resulting advisory range was 294 to 346 months.

In his allocution, Bentley stated that the district court has “two criminal jurisdictions[:]

One . . . under the common law and the other . . . [by] contract under . . . admiralty maritime

jurisdiction.” Sentencing Tr., R. 245, PageID #3812–13. He argued that he had committed no

crime under common law because “no sworn injured party testified against” him and he had “not

consented to any contract with the United States giving over the authority to adjudicate [his]

rights . . . .” Id. at PageID #3813. Basically, according to Bentley, he was innocent of any

legitimate crime, and the government lacked jurisdiction over him. He added that the offense

conduct spanned only a few weeks and that a 20-year sentence for that limited participation in drug

trafficking would be unjust. He asked that the court impose his sentences concurrently, noted that

he wanted to return home to his daughter, and stated, “I know I made mistakes, but I’m a different

man, I’m a changed man.” Id. at PageID #3816.

-3- No. 24-5433, United States v. Bentley

In response to Bentley’s jurisdictional arguments, the district court stated:

I have tried a number of cases involving defendants who held these sovereign citizen-type views, never turned out well for any of them, defendants who come into this court and espouse various antigovernment views or claim that the court has no jurisdiction over them, claim that they’re above the law and they can suffer no consequences at the hands of the court, and who more often than not end up representing themselves because lawyers will not in good faith make those arguments. . . . [Y]ou will not win in the Sixth Circuit or in the U.S. Supreme Court on a claim that this court has no jurisdiction over criminal cases. You will not win on the argument that the only jurisdiction this court has is over common law offenses and contracts. Those are senseless arguments. They’ve never prevailed and they will not prevail this time . . . .

Id. at PageID #3817, 19. Then the district court methodically and thoroughly discussed several of

the 18 U.S.C. § 3553(a) sentencing factors: the seriousness of the offense, the need to promote

respect for the law, the need to protect the public, the need for adequate deterrence, the nature and

circumstances of Bentley’s involvement in the offense, and Bentley’s personal history and

characteristics. See 18 U.S.C. § 3553(a).

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