STATE OF GEORGIA v. HILL

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
MACON DIVISION
STATE OF GEORGIA, 	)
)
)
v. 	) 	CIVIL ACTION NO. 5:25-CV-539 (MTT)
)
JEFFREY ALLEN HILL, 	)
)
)
Defendant. 	)
)
ORDER
Jeffrey Allen Hill filed a “Second Notice of Removal Pursuant to 28 U.S.C. §
1443(1)” on December 11, 2025. ECF 1. Hill is attempting to remove “related criminal
actions pending in the Superior Court of Jones County, Georgia” which arise from his
arrest on August 26, 2025: Case No. 2024-CR-282 and Case No. 2025-WT-047. Id. at
1. Upon review of the second notice of removal in accordance with 28 U.S.C. §
1455(b)(4),1 the Court finds that these actions must be remanded.
This is the second time Hill has attempted to remove Case No. 2024-CR-282
pursuant to 28 U.S.C. § 1443(1). See State of Georgia v. Hill, 2025 WL 3164469 (M.D.
Ga. Nov. 12, 2025). Under 28 U.S.C. § 1455(b)(2), a second notice of removal may be
filed only on grounds not existing at the time of the original notice, except upon a
showing of good cause. Hill contends that his second notice of removal presents
1 28 U.S.C. § 1455(b)(4) provides: “The United States district court in which such notice [of removal] is
filed shall examine the notice promptly. If it clearly appears on the face of the notice and any exhibits
annexed thereto that removal should not be permitted, the court shall make an order for summary
remand.”
Case 5:25-cv-00539-MTT Document 8 Filed 01/12/26 Page 1 of 5

-2-
“genuinely new facts discovered after [the Court’s] remand” that “satisfy the ‘formal
expression’ or ‘settled practice’ requirement of Georgia v. Rachel.” ECF 1 at 3.
While not clear from Hill’s second notice of removal, according to his first notice
of removal, Hill is charged with obstructing an officer in violation of O.C.G.A. § 16-10-24
and identity fraud in violation of O.C.G.A. § 16-9-121(a)(4) in Case No. 2024-CR-282.
See State of Georgia v. Hill, No. 5:25-cv-00465-MTT, ECF 1-1, 1-2. However, public
documents reflect that in Case No. 2024-CR-282, Hill is charged with driving with an
expired tag in violation of O.C.G.A. § 40-2-8. Hill does not explain the “new charges”
brought in Case No. 2025-WT-047, and the Court does not know what those are. See
ECF 1.
A. Hill’s Second Notice of Removal is Procedurally Defective.
Upon reviewing Hill’s first notice of removal, the Court concluded that Case No.
2024-CR-282 was untimely removed under 28 U.S.C. § 1455(b)(1) and Hill failed to
show good cause. See State of Georgia v. Hill, No. 5:25-cv-00465-MTT, ECF 3. Hill’s
second notice of removal is likewise not timely filed, and he has not, and cannot, show
good cause for failing to timely remove his case. He asserts that his second notice of
removal is timely because he filed a motion for reconsideration in the state court that
has been pending for 74 days and the “74-day pattern of systemic refusal did not exist
on October 24, 2025 (first removal date).” ECF 1 at 5. As will be further explained
below, a 74-day delay by the state court in ruling on a pending motion, and Hill’s other
“new facts,” are not grounds for removal under § 1443(1) and cannot satisfy the good
cause standard. Hill’s second notice of removal is also defective under 28 U.S.C. §
1455(a) because it does not contain “a short and plain statement of the grounds for
Case 5:25-cv-00539-MTT Document 8 Filed 01/12/26 Page 2 of 5

-3-
removal, together with a copy of all process, pleadings, and orders served upon such
defendant or defendants in such action.” Hill’s 63-page second notice of removal lacks a
short and plain statement of the basis for removal and does not include copies of the
state court process, pleadings, and orders. ECF 1.
B. The Court Lacks Jurisdiction.
Hill has not shown in his second notice of removal any basis for finding that his
criminal actions fall within the narrow grounds for removal permitted under § 1443(1).
See State of Georgia v. Hill, No. 5:25-cv-00465-MTT, ECF 3 at 2-3 (describing grounds
for removal under § 1443). As Hill is aware, removal under § 1443(1) requires two
elements: (1) denial of a right bestowed by “a federal law providing for specific civil
rights stated in terms of racial equality”; and (2) inability to “enforce the specified federal
rights in the courts of (the) State.” Johnson v. Mississippi, 421 U.S. 213, 219
(1975) (parentheses in original) (internal quotations and citations omitted). It is
presumed that state courts can enforce federal statutory and constitutional law, “except
in the rare situations where it can be clearly predicted by reason of the operation of a
pervasive and explicit state or federal law that those rights will inevitably be denied by
the very act of bringing the defendant to trial in the state court.” Id. at 220 (quoting
Greenwood v. Peacock, 384 U.S. 808, 828 (1966)).
Addressing the first prong, Hill claims that 42 U.S.C. § 1981 and § 1982 apply to
his state court criminal prosecution because the state “refus[es] to recognize” his
“Hebrew Israelite” and tribal identities and selectively uses the identity-fraud statute to
discriminate against him.” ECF 1 at 6-9. He maintains that he has been racially
discriminated against in violation of § 1981 because he cannot exercise his federal
Case 5:25-cv-00539-MTT Document 8 Filed 01/12/26 Page 3 of 5

-4-
contract rights, including the federal trademark of his name, his “Federal DOT
Authorization,” and his “Federal Bonding Contract.” Id. at 8. Relatedly, Hill argues that
his rights under § 1982 have been violated because “[s]tate actors” have “[s]eized
federal trademark material without proper receipts; [i]nterfered with federally-protected
intellectual property; [and] [c]riminalized use of property (registered trademark) based
on discriminatory treatment of Defendant’s racial and tribal identity.” Id.
Sections 1981 and 1982 qualify as laws providing for equal civil rights within the
meaning of § 1443(1). Greenwood, 384 U.S. at 825 (1966); see Georgia v. Rachel, 384
U.S. 780 at n.12. However, far from invoking these civil rights statutes in good faith,
Hill’s arguments and filings in this case contain language suggestive of the sovereign
citizen movement. To the extent that Hill attempts to assert sovereign citizen ideology in
this case, courts have uniformly rejected such arguments as completely meritless.
See Mackey v. Bureau of Prisons, 2016 WL 3254037, at *1 (E.D. Cal. June 14,
2016) (noting that “[c]ourts across the country” have rejected sovereign citizen
arguments “as frivolous, irrational, or unintelligible”). Moreover, “advancement of such
utterly meritless arguments is now the basis for serious sanctions imposed on civil
litigants who raise them.” United States v. Studley, 783 F.2d 934, 937 n.3 (9th Cir.
1986).2
2 Hill is aware of this Court’s intolerance for sovereign citizen theories. See Hill-Yisra’el v. Paxton, 2024
WL 4993890, at *1 (M.D. Ga. Feb. 8, 2024) (“The ‘outlandish’ legal theories launched by sovereign
citizens have been consistently rejected as described as ‘patently ludicrous.’ Plaintiff's case is no
different.”) (internal citations omitted). Nonetheless, Hill filed three notices of tribal sovereign immunity in
this case, which have no lawful effect in this Court. ECF 5, 6, 7. To the extent Hill seeks to argue that he
is immune from state criminal prosecution by way of his “tribal identity” as a “Hebrew Israelite” and
“Ambassador for Achukma Nation” (ECF 1 at 3), this theory is indisputably meritless. See United States v.
Benabe, 654 F.3d 753, 767 (7th Cir. 2011) (“Theories of individual sovereignty, immunity from
prosecution, and their ilk … should be rejected summarily, however they are presented.”).
Case 5:25-cv-00539-MTT Document 8 Filed 01/12/26 Page 4 of 5

-5-
Even if the Court assumes that Hill’s allegations satisfy the first element, he
provides no reason to disturb the presumption that the state court can enforce his civil
rights. See Johnson, 421 U.S. at 219-20. Hill argues that he cannot enforce his rights in
state court because (1) the state court’s September 12, 2025 order “refused immediate
jurisdictional analysis”; (2) the state court has not ruled on Hill’s motion for
reconsideration for 74 days; (3) the state court has not ruled on Hill’s motion to compel
for 48 days; (4) a new state court prosecution against Hill, Case No. 2025-WT-047, was
filed and scheduled for trial without considering Hill’s defenses; and (5) the District
Attorney stated that “Georgia does not accept [tribal] sovereign status.” ECF 1 at 9-12.
But as the Court has already explained, “[i]t is not enough to support removal under §
1443(1) to allege or show that the defendant’s federal equal civil rights have been
illegally and corruptly denied by state administrative officials in advance of trial, that the
charges against the defendant are false, or that the defendant is unable to obtain a fair
trial in a particular state court.” Greenwood, 384 U.S. at 827.
Because Hill has no statutory basis for removal, his criminal actions are
REMANDED to the state court. The Clerk of Court is DIRECTED to close this case and
to transmit a certified copy of this Order of Remand to the Superior Court of Jones
County, Case No. 2024-CR-282 and Case No. 2025-WT-047.3
SO ORDERED, this 12th day of January, 2026.
S/ Marc T. Treadwell
MARC T. TREADWELL, JUDGE
UNITED STATES DISTRICT COURT
3 Hill’s motion for leave to proceed in forma pauperis (ECF 2), emergency motion for a temporary
restraining order (ECF 3), and motion to dismiss for lack of jurisdiction (ECF 4) are DENIED as moot.
Case 5:25-cv-00539-MTT Document 8 Filed 01/12/26 Page 5 of 5