United States of America v. Michael Oliver

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted January 13, 2026*
Decided January 14, 2026
Before
MICHAEL B. BRENNAN, Chief Judge
MICHAEL Y. SCUDDER, Circuit Judge
NANCY L. MALDONADO, Circuit Judge
No. 25-1537
UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
MICHAEL OLIVER,
Defendant-Appellant.
Appeal from the United States District
Court for the Southern District of
Illinois.
No. 3:24-CR-30108-DWD
David W. Dugan,
Judge.
O R D E R
Michael Oliver, acting pro se, appeals his conviction for being a felon in
possession of a firearm as an armed career criminal. His only arguments on appeal are
frivolous sovereign-citizen theories, so we affirm.
* We have agreed to decide the case without oral argument because the appeal is
frivolous. F ED. R. A PP . P. 34(a)(2)(A).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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No. 25-1537 Page 2
After Oliver admitted to having a gun in his car during a high-speed chase
through the streets of Nashville, Illinois, a grand jury indicted him on one count of
possessing a firearm as a felon. 18 U.S.C. § 922(g)(1). Because he had three prior felonies
for battery and drug trafficking, the grand jury later charged him in a superseding
indictment as an armed career criminal. Id. § 924(e). Dissatisfied with his lawyer, Oliver
moved to represent himself. The court conducted a Faretta hearing, assured itself that
Oliver was competent to represent himself, and granted his motion. See Faretta v.
California, 422 U.S. 806, 835 (1975). The case proceeded to a jury trial where Oliver was
found guilty of being a felon-in-possession and an armed career criminal. See Erlinger v.
United States, 602 U.S. 821, 835 (2024).
In the leadup to his sentencing hearing, Oliver filed two motions that, in effect,
sought to have the indictment dismissed. The motions asserted that he was immune
from prosecution because he is the king of a foreign nation, a divine being in mortal
form, and a corporate entity. The district court, recognizing these as frivolous
sovereign-citizen arguments, summarily denied the motions. Oliver filed an
interlocutory appeal advancing those same theories of immunity; we dismissed the
appeal, agreeing with the district court that his arguments were frivolous. United States
v. Oliver, No. 25-1138 (7th Cir. Mar. 28, 2025). Once the case returned to the district
court, Oliver was sentenced to 240 months in prison.
On appeal, Oliver continues to represent himself and reasserts his sovereign-
citizen arguments. He purports to be immune from prosecution because he is a foreign
sovereign (the “King of the Black Hebrew Nation-State”) and a divine being (“The One,
The Lord, The King of Israel, The One enthroned in Heaven”), and that the district court
sentenced only his “corporate” form. But as we told Oliver when dismissing his
interlocutory appeal, these arguments are frivolous and we will not engage with them.
See United States v. Benabe, 654 F.3d 753, 767 (7th Cir. 2011) (collecting cases on
sovereign-citizen theories); Turkiye Halk Bankasi A.S. v. United States, 598 U.S. 264, 272
(2023) (Foreign Sovereign Immunities Act does not provide immunity in criminal
proceedings).
Oliver’s conviction is AFFIRMED and his pending motion to stay his sentence is
DENIED.

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