Bradshaw Genard Nunnally v. Fraternal Order of Police, Illinois State Troopers Lodge No. 41

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted July 28, 2026*
Decided July 28, 2026
Before
MICHAEL Y. SCUDDER, Circuit Judge
AMY J. ST. EVE, Circuit Judge
NANCY L. MALDONADO, Circuit Judge
No. 25-3001
BRADSHAW GENARD NUNNALLY,
Plaintiff-Appellant,
v.
FRATERNAL ORDER OF POLICE,
ILLINOIS STATE TROOPERS LODGE
NO. 41, et al.,
Defendants-Appellees.
Appeal from the United States District
Court for the Southern District of
Illinois.
No. 3:25-cv-1916-DWD
David W. Dugan,
Judge.
O R D E R
Bradshaw Nunnally appeals the judgment dismissing his civil rights action that
alleged violations in connection with a traffic stop. We affirm.
* The appellees were not served with process and are not participating in this
appeal. We have agreed to decide the case without oral argument because the brief and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. FED. R. APP. P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with FED. R. APP. P. 32.1

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No. 25-3001 Page 2
We draw the following facts from Nunnally’s complaint and attached
documents. See J.B. v. Woodard, 997 F.3d 714, 717 (7th Cir. 2021). In May 2025, Nunnally
was stopped and detained by an Illinois state police officer for driving without a
license, registration, and automobile insurance. Illinois v. Hannibal Hagan, Case No.
2025-MT-001080 (Madison County). (These charges are pending in Illinois state court.)
The officer issued Nunnally four unspecified citations and confiscated what he
described as his “private license plate, not issued under the corporate franchise known
as the ‘Secretary of State’”; his “insurance card, a document evidencing private
contractual protection”; and his “Traveler Authorization Card, a document lawfully
attesting to [his] right to freely travel under common law.” It appears that these
documents were issued by ANPC International, an organization that identifies itself as
a “private and independent nation.” He later filed a complaint with the Illinois
Attorney General’s Disability Rights Bureau, citing violations of the Magna Carta and
common law inheritance laws.
Nunnally later sued the officer, the Illinois State Police, the Fraternal Order of
Police, and the Illinois Attorney General for alleged violations of his civil rights.
See 42 U.S.C. § 1983. Among the claims he raised was a deprivation of his rights
“secured by the Magna Carta 1215 anno domini, the Act of Supremacy 1559 anno
domini, the New Jersey Provincial Council 1702 anno domini, and the Treason Act
1351.” For these violations, Nunnally sought damages, injunctive relief from
prosecution, and a declaratory judgment that the defendants’ conduct violated the
Constitution and his “sovereign rights.”
The district court screened the complaint, see 28 U.S.C. § 1915(e), and dismissed
Nunnally’s claims based on the abstention doctrine set forth in Younger v. Harris,
401 U.S. 37 (1971). Regarding the claims for injunctive and declaratory relief, the court
concluded that it needed to abstain from the underlying state criminal proceedings that
were ongoing. As for Nunnally’s claims for damages, the court acknowledged that such
claims ordinarily are stayed rather than dismissed, see Simpson v. Rowan, 73 F.3d 134,
138–39 (7th Cir. 1995), but Nunnally’s claims did not require a stay because they were
premised on sovereign-citizen theories and therefore frivolous.
On appeal, Nunnally challenges the district court’s determination that his action
was frivolous and insists that he raised legitimate constitutional claims not rooted in
sovereign-citizen ideology. But we have summarily rejected similar sovereign-citizen
arguments, that is, arguments premised on the theory that the defendant is a sovereign
beyond the courts’ jurisdiction. See United States v. Benabe, 654 F.3d 753, 767 (7th Cir.

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No. 25-3001 Page 3
2011) (collecting cases on sovereign-citizen theories); Bey v. State, 847 F.3d 559, 559–61
(7th Cir. 2017) (affirming dismissal of a civil complaint premised on sovereign-citizen
ideology). Here, Nunnally asserted that the police did not have the authority to issue
him citations, and that the Illinois state court to which he had been summoned lacked
jurisdiction over his person. These theories have “no conceivable validity in American
law,” see United States v. Jonassen, 759 F.3d 653, 657 n.2 (7th Cir. 2014) (quoting United
States v. Schneider, 910 F.2d 1569, 1570 (7th Cir. 1990)), and the district court was within
its discretion to dismiss them. See 28 U.S.C. § 1915(e)(2)(B) (“[T]he court shall dismiss
the case at any time if the court determines that … the action … is frivolous.”); see also
Marts v. Hines, 68 F.3d 134, 135 (5th Cir. 1995) (when evaluating whether to stay or
dismiss a damages claim under Younger, a district court should make “the threshold
determination whether the action is frivolous”).
Nunnally also argues that the court should have granted him leave to amend
before dismissing his case with prejudice. Generally, a plaintiff is entitled to amend the
complaint once as a matter of right, and a district court should “freely give leave [to
amend] when justice so requires.” FED. R. CIV. P. 15(a). But district courts may deny
leave to amend when “the amendment would be futile.” Arreola v. Godinez, 546 F.3d 788,
796 (7th Cir. 2008). Here, the court correctly decided that Nunnally’s allegations are
incurably frivolous. In any event, a district court does not “abuse its discretion by
failing to order, sua sponte, an amendment to [the complaint] that [the plaintiff] never
requested.” See Chaidez v. Ford Motor Co., 937 F.3d 998, 1008 (7th Cir. 2019) (internal
citation omitted).
AFFIRMED

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