Marguerite Latete Kilpatrick

UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF OHIO
WESTERN DIVISION
In re:
Marguerite Latete Kilpatrick,
Debtor.
:
:
:
:
:
Case No. 25-30619
Chapter 7
Judge Crist
MEMORANDUM OPINION AND ORDER DENYING MOTION FOR RECUSAL
AND DISQUALIFICATION OF THE HONORABLE TYSON A. CRIST PURSUANT
TO 28 U.S.C. § 455(a) AND (b) (Doc. 101)
I. 	Introduction
This matter is before the Court on former and currently barred Debtor, Marguerite Latete
Kilpatrick’s (“Ms. Kilpatrick”), Motion for Recusal and Disqualification of the Honorable Tyson
A. Crist Pursuant to 11 U.S.C. § 455(a) and (b) (Doc. 101) (the “Motion to Recuse”). For the
reasons stated herein, the Motion to Recuse is hereby denied.
II. 	Jurisdiction
As part of its limited “clean up” jurisdiction that it retained notwithstanding the dismissal
of this chapter 7 case through the Order Granting U.S. Trustee’s Motion to Dismiss with Prejudice
and One (1) Year Bar to Refiling (Doc. 79) (the “Dismissal and Bar Order”), and as addressed in
the Memorandum Opinion and Order: (I) Rejecting Papers Received from the Former, Presently
Barred, Debtor to Initiate an Adversary Proceeding in a Dismissed Case for Lack of Subject
This document has been electronically entered in the records of the United
States Bankruptcy Court for the Southern District of Ohio.
IT IS SO ORDERED.
Dated: June 8, 2026
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Matter Jurisdiction; and (II) Ordering the Clerk to Return the Original Papers to the Former
Debtor (the “Order Rejecting Adversary Proceeding”) the Court is contemporaneously entering
on Ms. Kilpatrick’s attempt to initiate a new adversary proceeding in this dismissed case, this
Court has jurisdiction over the Motion to Recuse filed by Ms. Kilpatrick pursuant to 28 U.S.C.
§ 1334(b) and Amended General Order 05-02 (Amended Standing Order of Reference) of the
United States District Court for the Southern District of Ohio, entered pursuant to 28 U.S.C.
§ 157(a), as well as 11 U.S.C. §§ 105(a), 349(b)(3), and its inherent authority because the Court
retained limited jurisdiction specifically for the purpose of considering whether to sanction Ms.
Kilpatrick for her conduct and filings submitted in this case pursuant to Federal Rule of Bankruptcy
Procedure (“Bankruptcy Rule”) 9011(b). In re Balistreri, No. 4:25-bk-2956, 2025 Bankr. LEXIS
3326, at *6-7 & n.8 (Bankr. M.D. Pa. Dec. 23, 2025) (citing Cooter & Gell v. Hartmarx Corp.,
496 U.S. 384, 385 (1990) (holding “that ‘[i]f a litigant could purge his Rule 11 violation merely
by taking a dismissal, he would lose all incentive to investigate more carefully before serving and
filing papers.’ ”).
III. 	Background
The above-captioned chapter 7 case filed by Ms. Kilpatrick pro se on April 8, 2025 (Doc. 1)
was dismissed on October 1, 2025, with a one (1) year bar to refiling. This was based on the United
States Trustee’s Motion to Dismiss with Prejudice (Doc. 38) (the “Motion to Dismiss”) filed on
July 31, 2025, and the United States Trustee’s Supplemental Memorandum in Support of Motion
to Dismiss with Prejudice (Doc. 52) (the “Memorandum in Support”). The U.S. Trustee’s
Memorandum in Support, which was filed in response to this Court’s Order Requiring a
Supplemental Filing Concerning the United States Trustee’s Motion to Dismiss with Prejudice
(Doc. 38) (Doc. 48), sums up the reasons why Ms. Kilpatrick’s third bankruptcy case filed in the
span of just over seven months1 was dismissed with a one (1) year bar to refiling:
1 Ms. Kilpatrick’s previous two pro se chapter 13 cases, filed on August 22, 2024 (No. 24-31598) and December 17,
2024 (No. 32461), were both dismissed on a motion to dismiss for cause filed by the Chapter 13 Trustee. See Case
No. 24-31598, Docs. 16, 21, 23 (dismissing her case because she failed to file a chapter 13 plan; however, a second
motion to dismiss was pending because the meeting of creditors could not be conducted and she had failed to
commence payments within thirty days); Case No. 24-32461, Docs. 16, 17 (dismissing her second case also because
she failed to file a chapter 13 plan). In her first chapter 13 case, rather than file a plan or comply with her duties, Ms.
Kilpatrick filed a Writ of Quo Warranto (Doc. 19) containing sovereign citizen type assertions. In her second chapter
13 case, after the dismissal order was entered Ms. Kilpatrick began to submit more sovereign citizen type documents,
such as the Legal Notice (Doc. 21), to which she attached a Notice of Interest, Notice of Beneficial Ownership,
Revocation of Power of Attorney, Declaration of Non-Corporate Status, and Notice of Fiduciary Duty.
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The undisputed facts of this case demonstrate that the Debtor is a serial filer that
repeatedly files for bankruptcy protection on the eve of the foreclosure sale of the
Property and who has failed to comply with the Trustee’s reasonable, routine, and
repeated requests for information and documents. The Debtor’s conduct in this case
constitutes bad faith and cause for the dismissal of this case, with prejudice, under
11 U.S.C. § 707(a).
Memo. in Supp. at 2, ¶ 7.2 Previously, within the Motion to Dismiss, the U.S. Trustee had
characterized Ms. Kilpatrick as “a serial bankruptcy filer who is using her bankruptcy filings to
improperly delay a pending foreclosure proceeding before the Montgomery County Court of
Common Pleas[,]” Case No. 2023 CV 04539 (the “Foreclosure Action”). Mot. to Dismiss at 1.
Also attached to the U.S. Trustee’s Motion to Dismiss was the Declaration of Patricia J. Friesinger,
the Chapter 7 Trustee appointed in Ms. Kilpatrick’s chapter 7 case (“Ms. Friesinger”). Mot. to
Dismiss, Ex. A. Ms. Friesinger described her difficulties in obtaining financial information from
Ms. Kilpatrick, which was necessary for her to comply with her duties as Chapter 7 Trustee.
Moreover, after Ms. Kilpatrick failed to show for all four scheduled meeting of creditors, the
Chapter 7 Trustee closed the meeting. See supra note 1.
Following the filing of the U.S. Trustee’s Motion to Dismiss, and subsequent to the conduct
that warranted barring her from filing any further bankruptcy cases for one (1) year, Ms. Kilpatrick
began to file what ended up being a total of twenty-seven (27) filings with this Court (Docs. 44,
45, and 53-77) (the “Filings”), not in her capacity as a “natural person,” but as, amongst other
assumed titles, an “Ambassador for Christ and Minister within The Embassy of Living Faith TM .”
See Ministerial Decl. of Fiduciary Breach and Judicial Trespass (Doc. 53) at 4. Thus, in order to
address 	Ms. 	Kilpatrick’s 	numerous 	filings 	in 	full 	(rather 	than 	summarily 	reject 	them),
contemporaneous with entering the Dismissal and Bar Order on October 1, 2025, the Court
2 Out of an abundance of caution, the Court entered the Order Requiring a Supplemental Filing Concerning the United
States Trustee’s Motion to Dismiss with Prejudice (Doc. 38) (Doc. 48) (Doc. 48) because it appeared from the docket
that Ms. Kilpatrick had appeared for her meeting of creditors on August 18, 2025, approximately one (1) month after
the U.S. Trustee had filed his Motion to Dismiss (Doc. 38), and the Court wanted to know whether this changed the
position of the U.S. Trustee that Ms. Kilpatrick’s case should be dismissed, and dismissed with a bar to refiling.
However, as set forth in the Supplemental Declaration of Patricia J. Friesinger (Doc. 52-1), attached to the
Memorandum in Support, “[t]he fourth scheduled 341 Meeting of Creditors was set to be heard on August 7, 2025”
and “[t]he Debtor failed to attend the meeting” and failed “to produce the documents after multiple attempts” by the
Chapter 7 Trustee to obtain those documents as set forth in her prior Declaration of Patricia J. Friesinger (Doc. 38-1),
such that the docket entry was incorrect that the meeting of creditors had been held; rather, the Chapter 7 Trustee
simply concluded the meeting because it was the fourth time it had been scheduled and Ms. Kilpatrick never appeared.
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prepared and entered its eleven (11) page Order Denying All Filings,3 in which the Filings were
accurately described therein as follows:
It is readily apparent that the Filings, perhaps best described as missives,
are a convoluted linguistic effort, built on baseless artificial constructs that lack any
legal basis, similar to or in the same nature and vein as sovereign citizen theories,
to dream up an alternate reality in which everyone potentially owes money to the
Debtor’s trust, rather than the Debtor owing money to creditors, which is what this
case was actually about. And the Filings were clearly intended by the Debtor to
threaten innocent people who have done absolutely nothing wrong, nor anything to
invite these baseless threats of monetary liability for a slew of completely made-up
offenses. The Filings are frivolous and harassing. And this is not the first
bankruptcy case before this Court in which Ms. Kilpatrick has submitted such
baseless filings. See No. 24-32461 (Bankr. S.D. Ohio) (Legal Notice (Doc. 21),
including a number of similar filings); No. 24-31598 (Bankr. S.D. Ohio) (Writ of
Quo Warranto (Doc. 19), including similar filings).
The themes invoked by the Debtor in her Filings are “commonly associated
with the so-called ‘sovereign citizen’ movement” and “have been uniformly
rejected by every federal court to confront them.” [In re] Morgan-Grant, [No.
24-18665-PDR,] 2025 Bankr. LEXIS [1335,] at *2[, 2025 WL 1571024 (S.D. Fla.
June 3, 2025) (“addressing similar baseless legal theories relating to a ‘private
ecclesiastical trust’ ”)] (citing United States v. Williams, 29 F.4th 1306, 1308 (11th
Cir. 2022); United States v. Sterling, 738 F.3d 228, 233 n.1 (11th Cir. 2013)). “The
rule of law is not so fragile as to be undone at the whim of a litigant through
invocation of spiritual sovereignty or divine right. Federal jurisdiction cannot be
waived or revoked by incantation.” Id. at *2.“There is no parallel legal system
grounded in personal belief that exempts one from the obligations of debt, the
authority of a duly appointed trustee, or the jurisdiction of this Court.” Id. at *7.
Previous courts within the Sixth Circuit have found that these types of arguments
lack merit. See Clinton v. Coyaleski, No. 4:25-cv-1363, 2025 U.S. Dist. LEXIS
186480, 2025 WL 2711413 (N.D. Ohio Sept. 23, 2025) (collecting cases that reject
jurisdictional arguments based on similar sovereign citizen arguments), Watts v.
Cleveland Heights, No. 1: 25 CV 1582, 2025 U.S. Dist. LEXIS 176338, 2025 WL
2615846 (N.D. Ohio Sept. 10, 2025) (finding Defendant’s arguments claiming that
that he was not subject to traffic laws, similar to those advanced in the filings, as
being “devoid of merit”), and Burks v. Licking Cnty. Child Support Enf’t Agency,
No. 2:24-cv-2330, 2025 U.S. Dist. LEXIS 31341, 2025 WL 580389 (S.D. Ohio
3 See Order: (I) Denying All Assertions, Purported Claims, Relief, and All Other Matters Set Forth in Filings Received
from Debtor on September 2, 2025 (Docs. 44 & 45) and on September 24, 26, 29 and 30, 2025 (Docs. 53 through 77);
(II) Giving Notice to Debtor that the Filings Violate Federal Rule of Bankruptcy Procedure 9011(a) and Will be
Stricken if Not Withdrawn; (III) Requiring Debtor to Show Cause Why She Has Not Violated Rule 9011(b) if the
Papers are Not Withdrawn; and (IV) Ordering the Immediate Return of All Purported Tenders as Expressly Rejected
and Not Recognized by Law (Doc. 78) (the “Order Denying All Filings”).
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Feb. 21, 2025) (describing the voluminous filings related to sovereign citizen
arguments as frivolous and wasteful of court resources).
Order Denying All Filings at 2. And for those reasons, the Court denied any and all relief sought
through the Filings, as explained therein as follows:
After a careful review of the Filings, the Court is unable to discern any relief
requested by the Debtor that is available under Title 11 of the United States Code
(the 	“Bankruptcy 	Code”) 	or 	the 	Federal 	Rules 	of 	Bankruptcy 	Procedure.
Accordingly, all of the Filings are hereby DENIED with prejudice, and the Clerk
of Court is hereby instructed to forthwith return all of the original Filings, which
the Court rejects and does not accept tender of, to the Debtor by first class U.S.
mail. In addition, the Court hereby, as more fully set forth below, gives notice to
the Debtor that her Filings will be stricken as not properly signed in her individual
capacity and lacking her current address and telephone number, all as required by
Rule 9011(a) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy
Rules”), within seven (7) days from the date of entry of this Order.
In the alternative, Debtor may withdraw her Filings through submitting a
notice of withdrawal properly signed in accordance with Bankruptcy Rule 9011(a),
which must be filed within seven (7) days from the date of entry of this Order.
Absent withdrawal, the Filings will be stricken.
If, however, the Filings are not withdrawn, then Debtor shall show cause,
within twenty-one (21) days from the date of entry of this Order, why she has not
violated Bankruptcy Rule 9011(b) by submitting the Filings to this Court, which
were presented for an improper purpose, such as to harass the Court and the people
named therein, have caused unnecessary delay, contain legal contentions not
warranted by existing law or by nonfrivolous arguments, and contain allegations
and factual contentions that lack any evidentiary support.
Order Denying All Filings at 2-3.
At the same time that the Court entered its Order Denying All Filings, as mentioned above
the Court granted the U.S. Trustee’s Motion to Dismiss and this case was dismissed with a one-
year bar to refiling. See Dismissal and Bar Order (Doc. 79). However, the Court retained “clean
up” jurisdiction solely in order to “address the matters set forth in the Order Denying All Filings[,]”
in order to conduct a hearing to determine whether to impose sanctions pursuant to Bankruptcy
Rule 9011(b) in accordance with the Court’s inherent right to control its own docket. Dismissal
and Bar Order at 6, ¶ 7; Order Denying All Filings at 10. As cited above, former Debtor, Ms.
Kilpatrick, was given seven (7) days to withdraw her numerous frivolous filings (Docs. 44, 45,
and 53-68), absent which Ms. Kilpatrick was directed to show cause within twenty-one (21) days
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why she should not be held in contempt for violating Federal Rule of Bankruptcy Procedure
(“Bankruptcy Rule”) 9011(b), absent which the Court may proceed to issue sanctions in
accordance with Bankruptcy Rule 9011(c)(1)-(4). Ms. Kilpatrick did not attempt to show cause,
but the Court has not proceeded to impose sanctions and will not do so before holding a hearing.
Following the Order Denying All Filings (Doc. 78) and Dismissal and Bar Order (Doc.
79), both entered on October 1, 2025, Ms. Kilpatrick filed a Motion to Withdraw the Reference
(Doc. 86) and an Emergency Motion for Stay Pending Determination of Motion to Withdraw the
Reference (Doc. 85), both on October 28, 2025, in an effort to prevent this Court from proceeding
with holding a hearing to consider whether to impose sanctions on her as a result of her
twenty-seven sovereign citizen themed Filings. The Court entered an Order Denying Former
Debtor’s Emergency Motion for Stay Pending Determination of Motion to Withdraw the Reference
(Doc. 89) (the “Order Denying Stay”) and Report and Recommendation Concerning Motion to
Withdraw the Reference (Doc. 90) (the “Report and Recommendation”) on November 24, 2025.4
Ms. Kilpatrick filed a Motion for Reconsideration of Orders and Request to Docket Revised
Procedural 	Notice 	Regarding 	Potential 	Competing 	Claims 	(Doc. 	94) 	(the 	“Motion 	for
Reconsideration”), which was denied (Doc. 98). Ms. Kilpatrick then filed a Motion for Recusal
and Disqualification of the Honorable Tyson A. Crist Pursuant to 28 U.S.C. § 455(a) and (b) (Doc.
101) (the “Motion to Recuse”). The majority of Ms. Kilpatrick’s argument in her Motion to Recuse
relates to this Court’s Order Denying Stay and Report and Recommendation, both entered on
November 24, 2025, concerning her Emergency Motion for Stay and Motion to Withdraw the
Reference, neither of which this Court found to have any merit, but which the applicable statute
requires the District Court to determine.
Ms. Kilpatrick asserts that this Court’s Order Denying Stay “contains extensive language
that demonstrates personal bias, prejudice, and prejudgment against Movant.” Recusal Mot. at 2,
¶ 5. Ms. Kilpatrick argues that “[t]he language and tone of the Order, as detailed below, would
cause a reasonable, well-informed observer to question the Court’s impartiality.” Id. at 2, ¶ 6. She
also argues that this Bankruptcy Judge’s prior findings that her filings have been frivolous and
may warrant sanctions pursuant to Bankruptcy Rule 9011(b), for which it has retained “clean up”
4 The Motion to Withdraw the Reference is pending before the District Court for the Southern District of Ohio, Case
No. 3:25-cv-00436-MJN.
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jurisdiction, reflects that the outcome “would be a predetermined proceeding with a foregone
conclusion, not a genuine opportunity to be heard.” Id. at 4-5, ¶¶ 11-13. These assertions will be
addressed below.
IV. 	Law of Disqualification
Bankruptcy Rule 5004(a), which concerns recusal of a bankruptcy judge (other than with
respect to allowing compensation), provides as follows:
A bankruptcy judge’s disqualification is governed by 28 USC § 455. The judge is
disqualified from presiding over the proceeding or contested matter in which a
disqualifying circumstance arises—and, when appropriate, from presiding over the
entire case.
Fed. R. Bankr. P. 5004(a). In turn, 28 U.S.C. § 455 states, as relevant to Ms. Kilpatrick’s Motion
to Recuse, that:
(a) Any justice, judge, or magistrate judge of the United States shall disqualify
himself in any proceeding in which his impartiality might reasonably be questioned.
(b) He shall also disqualify himself in the following circumstances:
(1) Where he has a personal bias or prejudice concerning a party. . . .
28 U.S.C. § 455(a) and (b)(1). The Court must recuse if statutory grounds exist, but “there is a
corresponding duty not to do so if cause for recusal has not been shown” in order to prevent judge
shopping and ensure orderly case administration. Barna v. Haas (In re Haas), 292 B.R. 167, 175
(Bankr. S.D. Ohio 2003) (Hoffman, J.) (collecting cases). Recusal is required when a judge’s
impartiality may be reasonably questioned by the objective, reasonable observer. In re Royal
Manor Mgmt., 525 B.R. 338, 380 (B.A.P. 6th Cir. 2015), aff’d sub nom Grossman v. Wehrle (In
re Royal Manor Mgmt.), 652 F. App’x 330 (6th Cir. 2016); In re Buchholz, No. 22-30584, 2022
Bankr. LEXIS 2576, at *8 (Bankr. S.D. Ohio Sept. 1, 2022) (Humphrey, J.) (quoting Haas, 292
B.R. at 175-76).
Recusal generally comes up in one of two scenarios. In re Buchholz, 2022 Bankr. LEXIS
2576, at *8. The first is when the judge is or becomes aware of information outside the record of
the judicial proceeding and forms an opinion based on that extrajudicial knowledge, “which is
referred to as the ‘Extrajudicial Source Doctrine.’ ” Id.; see also Haas, 292 B.R. at 176. Ms.
Kilpatrick’s Motion to Recuse makes no allegations suggesting that this situation exists. The
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second is “ ‘when a judge whose information is limited to that revealed during the course of
judicial proceedings forms a favorable or unfavorable opinion so extreme that fair judgment
appears impossible.’ ” Id., at *13 (quoting In re Nicole Energy Servs., Inc., 423 B.R. 840, 844-45
(Bankr. S.D. Ohio 2010) (Hoffman, C.J.); see also Haas, 292 B.R. at 176. This is referred to as
the “ ‘Pervasive Bias Exception.’ ” Id.
Notably, Ms. Kilpatrick’s assertions in the Motion to Recuse are focused on the Court’s
written decisions, which, in fact, are the only interactions that have occurred, Ms. Kilpatrick never
having been before the Court in-person. But “judicial rulings alone almost never constitute a valid
basis for a bias or partiality motion.” Liteky v. U.S., 510 U.S. 540, 555 (1994) (citing United States
v. Grinnell Corp., 384 U.S. 563, 583 (1966)). And “only in the rarest of circumstances” do judicial
rulings “evidence the degree of favoritism and antagonism” requiring recusal. Id. “Almost
invariably, they are proper grounds for appeal, not for recusal.” Id. Further, “opinions formed by
the judge on the basis of facts introduced or events occurring in the course of the current
proceedings, or of prior proceedings, do not constitute a basis for a bias or partiality motion unless
they display a deep-seated favoritism or antagonism that would make fair judgment impossible.”
Id. Additionally, even “expressions of impatience, dissatisfaction, annoyance, and [] anger” do not
“establish[] bias or partiality[,]” although those have not been alleged. Id. Ms. Kilpatrick has not
had any hearings or conferences (telephonic or in-person) in front of this Court during the
administration of her now-dismissed bankruptcy case (dismissed, without opposition, due to her
bad faith serial filings), such that Ms. Kilpatrick’s allegations of bias can only stem from the
judicial orders of this Court. A judge’s legal opinions or adverse decisions “do not, in themselves,
show bias.” Buchholz, 2022 Bankr. LEXIS 2576, at *17-18 (citing Liteky, 550 U.S. at 555-56;
Green v. Nevers, 111 F.3d 1295, 1303-04 (6th Cir. 1997)).
V. 	Analysis
A. 	Alleged Bias and Prejudice
The Court does not have any bias against or animus toward Ms. Kilpatrick; rather, its
decision to retain limited jurisdiction to determine sanctions under Bankruptcy Rule 9011(b) and
its somewhat lengthy orders are a direct result of her repeatedly filing papers with this Court
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asserting baseless, debunked sovereign citizen positions.5 Ms. Kilpatrick’s accusations of bias
seem to mostly stem from the Court’s unwillingness to accept or acknowledge as legitimate her
frivolous arguments which are not supported by law, and from using her own terminology to
discuss her Filings. But the bases alleged by Ms. Kilpatrick are not correct and do not require
recusal, and indeed recusal would violate established federal law interpreting 28 U.S.C. § 455.
Therefore, for the reasons detailed below, the Motion to Recuse will be denied.
1. 	Use of the Term “Sovereign Citizen”
Ms. Kilpatrick’s first specific concern is that “[t]he Order uses the pejorative term
‘sovereign citizen’ over thirty (30) times to characterize Movant and her filings.” But she cannot
have her cake and eat it too. If she files sovereign citizen documents with this Court, it will identify
them as such. There is no bias or prejudice in that regard, just the use of a well-established and
well-understood legal term for her Filings, as further explained below. At no point has the Court
expressed any “impatience, dissatisfaction, annoyance, [or] even anger” toward Mr. Kilpatrick and
simply calling her filings what they are does not evidence any bias or prejudice; rather, it is a direct
result of this Court taking the time to fully review and determine whether her Filings had any
legitimate basis and requested any available relief, and carefully reaching the conclusion that they
did not. Accordingly, her Filings rejected as lacking any merit because they squarely fit the
classification of sovereign citizen filings that are not based in existing and recognized law.
Ms. Kilpatrick further complains that “[w]hile a court may describe the legal theories
presented, the gratuitous and repetitive use of this loaded term – which carries strong negative
connotations – evidences personal bias rather than dispassionate legal analysis.” Recusal Mot. at
3, ¶ 7 (citing Liteky v. United States, 510 U.S. 540, 555 (1994)). The Court does not find the term
“sovereign citizen” gratuitous, particularly in regard to describing and thoroughly analyzing Ms.
Kilpatrick’s voluminous twenty-seven (27) Filings with this Court which, in fact, espoused
sovereign citizen theories, stated no valid claims for relief, and were, in fact, an utter waste of time,
which is why the Court issued the Order Denying All Filings, which Ms. Kilpatrick did not move
to reconsider or appeal. That is not a bias against Ms. Kilpatrick; rather, it is a matter-of-fact
5 The Court will not fully review the multiple prior filings and decisions, except as needed to address the Motion to
Recuse, but for a complete background on Ms. Kilpatrick’s cases with this Court, see Order Denying Former Debtor’s
Emergency Motion for Stay Pending Determination of Motion to Withdraw the Reference (Doc. 89) and the Report
and Recommendation Concerning Motion to Withdraw the Reference (Doc. 90).
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assessment of the Filings she made with this Court. She prepared, assembled, or signed them in
various capacities and filed them with this Court. Not buying into the baseless assertions contained
in those Filings and labeling them for what they actually are does not constitute bias; instead, it is
a result of this Court taking the time to fully consider her voluminous filings and ultimately
concluding that they did not establish or seek any legitimate relief, such that Ms. Kilpatrick should
not have submitted those filings. Again, if she does not want her filings so labeled, she should not
have filed them with this Court. Her status as a pro se party does not give her a free pass to do so.
See 28 U.S.C. § 1654 (permitting parties to proceed pro se); Riddle v. Greenberger (In re Riddle),
No. 19-8022, 2020 Bankr. LEXIS 1695, at *22, 24 (B.A.P. 6th Cir. June 29, 2020) (observing that
“[i]n the bankruptcy context, appearing before a court in a pro se status does not alleviate a debtor
of the procedural and substantive duties imposed by the Bankruptcy Code and Rules” (citations
omitted) and “[a] debtor’s pro se status also does not excuse a lack of good faith in a bankruptcy
proceeding” (citing Cusano v. Klein (In re Cusano), 431 B.R. 726, 736 (B.A.P. 6th Cir. 2010);
Fed. R. Bankr. P. 9011(b) (which specifically applies to an “unrepresented person” and requires
them to certify “that, to the best of the person’s knowledge, information, and belief formed after
an inquiry reasonable under the circumstances . . . . [that their document] (1) is not presented for
any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase litigation
costs; (2) the claims, defenses, and other legal contentions are warranted by existing law or by a
nonfrivolous argument to extend, modify, or reverse existing law; [and] (3) the allegations and
factual contentions have evidentiary support . . . .”).
The term “sovereign citizen” has been used by courts of all stripes to describe parties that
deny the jurisdiction of a court without any recognized basis and assert theories based on an
alternative jurisdiction or set of laws that simply do not exist within codified U.S. law. See Indiana
v. Cohill, No. 2:25-CV-00336-GSL-AZ, 2025 U.S. Dist. LEXIS 147109, at *2 (N.D. Ind. July 30,
2025), U.S. v. Mooney, No. 16-cv-2547, 2017 U.S. Dist. LEXIS 217881, at *8-9 (D. Minn. Nov.
2, 2017), Johnson v. One Main Fin., No. 3:25-6263-JFA-SVH, 2025 U.S. Dist. LEXIS 154619, at
*7-8 (D.S.C. July 3, 2025); Marissa Bryan, Note: Sovereign Citizens: A Response in Absence of
Direction, 17 Charleston L. Rev. 247, 250 (Winter, 2022) (“A sovereign citizen believes he or she
decides which laws to obey or ignore and believes he or she is above all laws.”). This term is the
recognized and understood one to describe filings that refer to an alternative set of invented legal
principles or jurisdiction unrelated to federal bankruptcy law. Id. In fact, the Montgomery County,
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Ohio Court of Common Pleas has likewise identified certain of Ms. Kilpatrick’s filings, even
before she filed them with this Court, as sovereign citizen filings that are recognized to be
“ ‘meritless’ ” and “ ‘wholly frivolous.’ ” Order Denying Stay at 7 (quoting Entry and Order at
1-3, Lakeview Loan Servicing, LLC v. Kilpatrick, No. 2023 CV 04539 (Mont. Cnty. C.P. Apr. 16,
2025) (quoting State v. Huelsman, 2023-Ohio-649, ¶ 14-15 (2d Dist.) (citations omitted))). If the
term has negative connotations, it is only because of the fundamental and recognized definition of
that term, which is that the filings are frivolous and a waste of time because they have no
recognized legal basis. Thus, accurate use of that terminology hardly reflects a bias. And,
interestingly, Ms. Kilpatrick does not deny that her filings espoused sovereign citizen theories, she
simply complains that the Court identified them as such.
Ms. Kilpatrick, in an apparent effort to stave off foreclosure, adopted sovereign citizen
theories within the Filings she signed in self-appointed capacities and filed with this Court. The
use of the term is not a description of Ms. Kilpatrick generally (this Bankruptcy Judge has never
met her in a Court hearing or outside of it, Ms. Kilpatrick never having attended a hearing so far).
And perhaps she has moved on from adopting those discredited theories. But her repeated Filings
that did not have basis in existing law – federal bankruptcy law as governed by the Bankruptcy
Code of 1978, as amended, the Federal Rules of Bankruptcy Procedure, and various other related
statutes and rules – were accurately identified as documents containing sovereign citizen theories.
In regard to those twenty-seven (27) Filings, as the saying goes, if it looks like a duck, swims like
a duck, and quacks like a duck, then it probably is a duck. See Exploring Indiana Highways 68
(2007) (compiled by Michael Heim) (attributing the original version of the quote to James
Whitcomb Riley (1849-1916)).
The Court’s concern with Ms. Kilpatrick’s Filings has nothing to do with her representing
herself pro se (“in propria persona”). This Court, like all federal bankruptcy courts, addresses
filings of parties representing themselves on a daily basis. Pro se parties often have difficulty
precisely describing legal arguments and are sometimes tripped up by procedural rules, which tend
to be complex in bankruptcy court. But established federal law addresses these issues, and the
Court attempts to get to the heart of the arguments of pro se parties to dispense justice and provide
them with a roadmap to guide them through the bankruptcy process. But in almost all of these
cases, the parties agree that the governing law is the Bankruptcy Code, and, generally speaking,
the Court and all parties are all working from the same laws, rules, and forms to move a case
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forward for debtors and creditors alike. Ms. Kilpatrick’s twenty-seven (27) Filings espoused
sovereign citizen theories that ignored that basic legal framework and, as carefully examined by
this Court, stated no claims to legitimate relief, such that they were frivolous and only caused
unnecessary delay and taxing of judicial resources.
Finally, the Court did not refer to Ms. Kilpatrick as a sovereign citizen, but rather was
consistently careful to describe her filings as containing sovereign citizen type theories. A few of
the passages contained in the Order Denying Stay (Doc. 89), which is the Order Ms. Kilpatrick
complains of, are as follows:
III. Background
A. 	Overview
The background to the present Motions is somewhat involved due to Ms.
Kilpatrick’s serial pro se bankruptcies, bad faith conduct, and her mountain of
sovereign citizen filings. Ms. Kilpatrick has abused the bankruptcy process, has
peppered this Court (and the Common Pleas Court) with sovereign citizen filings
and, through her current filings, continues to do so, in an on-going effort to retain
her real estate through frivolous legal maneuvers. This is notwithstanding that her
sovereign citizen filings, on which she bases the current Motions, have been
rejected by both the Common Pleas Court and this Court, and notwithstanding that
her underlying bankruptcy case was dismissed on October 1, 2025 (Doc. 79) with
a one (1) year bar to refiling. To give context to consideration of the present
Motions, this Court will attempt to briefly describe the history of Ms. Kilpatrick’s
travails.
* 	* 	*
Interestingly, Ms. Kilpatrick, prior to and soon after filing her third
bankruptcy case, had previously filed a number of sovereign citizen filings in the
Common Pleas Court. The Common Pleas Court dealt with some of her similar
submissions, months before she began to submit her sovereign citizen filings to this
Court, in an Entry and Order Striking Defendant’s Plea of Tender and Notice of
Special Deposit, entered on April 16, 2025 (the “Entry and Order”). Therein, the
Common Pleas Court wrote, in language similar to that later used by this Court in
rejecting her sovereign citizen filings, as follows:
This matter is before the Court on the Declaration of
Representative Capacity and Plea of Tender and Notice of Special
Deposit, both filed on April 7, 2025 by Defendant Marguerite Latete
Kilpatrick, and Plaintiff’s Response in Opposition to Plea of Tender
and Notice of Special Deposit, filed April 11, 2025. The Court does
not find Ms. Kilpatrick’s filings are proper and the filings are
therefore stricken.
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* 	* 	*
II. LAW AND ANALYSIS
In 	the 	instant 	filings, 	Ms. 	Kilpatrick 	makes 	several
statements that are consistent with the assertion of rights as a
sovereign citizen not subject to the Court’s jurisdiction. Plaintiff
contends Ms. Kilpatrick’s arguments related to tender, payment and
dismissal are meritless and should be summarily rejected, and the
property should proceed to judicial sale.
Sovereign citizen declarations have repeatedly been rejected
by numerous Ohio courts, including the Second District, and
arguments based on this theory have been routinely recognized as
“meritless” and “wholly frivolous.” See e.g., State v. Huelsman,
2023-Ohio-649, ¶ 14-15 (2d Dist.) citing Paris v. Galluzzo, 2015-
Ohio-3385, ¶ 47 (2d Dist.); State v. Few, 2015-Ohio-2292, ¶ 6 (2d
Dist.); State v. Brown, 2024-Ohio-4808, ¶ 14 (2d Dist.); Y.A.B. ex
rel. E.E.W. v. Wallace, 2023-Ohio-551, ¶ 10 (2d Dist.); In re S.H.O.,
2019-Ohio-645, ¶ 16 (2d Dist.).
* 	* 	*
As she has in this Court, and notwithstanding the Common
Pleas Court’s Entry and Order, she continued to file numerous
meritless sovereign citizen style papers with the Common Pleas
Court, as reflected on the public docket for the foreclosure action,
during the period from May 5, 2025 to June 4, 2025 (6 filings), and
from September 26, 2025 to October 6, 2025 (4 filings). Kilpatrick,
No. 2023 CV 04539.
Order Denying Stay at 6-8 (quoting Entry and Order at 1-3, Lakeview Loan Servicing, LLC v.
Kilpatrick, No. 2023 CV 04539 (Mont. Cnty. C.P. Apr. 16, 2025)) (bold type removed from
headings). Obviously, this Court is not the only one to find that Ms. Kilpatrick’s Filings were based
on sovereign citizen theories. Yet this Court closely examined Ms. Kilpatrick’s Filings, describing
them as follows:
F. 	Sovereign Citizen Filings and VNOI
While the Motion to Dismiss was pending, Ms. Kilpatrick
began to submit her multitude of “Embassy of Living Faith”
sovereign citizen filings. It began with duplicate copies of [a]
Ministerial Cover Letter addressed to “Dear Trustees de son tort”
asserting that “[t]his Ministerial Cover Letter tenders actual and
constructive notice of sacred ecclesiastical instruments under the
covering 	of 	The 	Embassy 	of 	Living 	Faith™, 	a 	private
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ecclesiastical trust estate established and administered under the
Government of God.” Doc. 44 at 1 (emphasis in original); Doc. 45
at 1. And it goes on from there. One of the many documents enclosed
with that cover letter was described as a “Verified Notice of
Interest (Instrument No. 004.01) (anchor instrument).” Doc. 44-1
(emphasis in original). The VNOI was signed by Ms. Kilpatrick,
albeit as “the Living Heir in Sacred Honor” as “Marguerite Latete
of the House of Kilpatrick,” with the titles “Beneficial Owner,”
“Equitable 	Titleholder,” 	“Authorized 	Agent,” 	and 	“Custodian
Ambassador for Christ and Minister within The Embassy of Living
Faith™.” VNOI (Doc. 44-1) at 9.
* 	* 	*
It is readily apparent that Ms. Kilpatrick is unsatisfied with
her loss or potential loss of her real estate; a matter she potentially
could have addressed through bankruptcy had she been willing to be
forthcoming and comply with her obligations as a debtor. However,
it is also readily apparent that the alleged interest she holds in 108
Barnside Drive, which she refers to as the “trust res,” is a self-
granted made-up interest based on her “Embassy of Living Faith”
strain of sovereign citizen theories. For just a flavor (example) and
because she did not attach it to her Motions, the portion of the VNOI
that 	appears 	to 	allegedly 	“grant” 	her 	interest, 	“under 	the
ecclesiastical jurisdiction of the Most High God (Psalm 24:1)” states
as follows:
VII. 	DECLARATION OF INTEREST
I, the Living Heir, pursuant to my exclusive standing
in trust and sacred duty to operate in honor, do
hereby declare, retain, and assert sole, superior,
equitable interest and beneficial title in and to the
Private Estate, including—but not limited to—every
derivative 	instrument 	styled 	in 	the 	ALL 	CAPS
designation.
These 	derivative 	instruments 	include, 	without
limitation, 	all 	records, 	securities, 	contracts,
agreements, and estate identifiers arising from, or
connected 	to, 	any 	and 	all 	presumed 	adhesion
contracts, public filings, certificates, applications,
administrative 	constructs, 	and 	commercial
encumbrances.
* 	* 	*
I further declare, preserve, and perfect the private,
ecclesiastical status as Custodian exercising full
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equitable dominion over the Private Estate-including
all originating and derivative instruments-under the
spiritual and legal covering of The Embassy of
Living Faith™.
This Verified Notice of Interest is not tendered by
private will alone, but as a formal ecclesiastical and
equitable 	act, 	made 	in 	obedience 	to 	divine
prompting and by spiritual discernment under the
authority of the Holy Spirit—who bears witness with
my spirit, confirms my ecclesiastical calling, and
secures all rights, titles, and beneficial interests
rightfully belonging to the Living Heir.
Spiritual Witness:
“The Spirit itself beareth witness with our spirit,
that we are the children of God: And if children,
then heirs, heirs of God, and joint-heirs with
Christ ...”
~ Romans 8: 16-17 ~
VNOI (Doc. 44-1) at 3-4 (emphasis in original).
This is what she alleges is the basis for her current Emergency Motion for
Stay, nothing else. It would be “free speech” outside of court, but it is frivolous and
sanctionable in court and creates no lawful rights. As this Court previously wrote
in its Order Denying All Sovereign Citizen Filings:
The themes invoked by the Debtor in her Filings are
“commonly 	associated 	with 	the 	so-called 	‘sovereign 	citizen’
movement” and “have been uniformly rejected by every federal
court to confront them.” Morgan-Grant, 2025 Bankr. LEXIS at *2
(citing United States v. Williams, 29 F.4th 1306, 1308 (11th Cir.
2022); United States v. Sterling, 738 F.3d 228, 233 n.1 (11th Cir.
2013)). “The rule of law is not so fragile as to be undone at the
whim of a litigant through invocation of spiritual sovereignty or
divine right. Federal jurisdiction cannot be waived or revoked by
incantation.” 	Id. 	at 	*2. 	“There 	is 	no 	parallel 	legal 	system
grounded 	in 	personal 	belief 	that 	exempts 	one 	from 	the
obligations of debt, the authority of a duly appointed trustee, or
the jurisdiction of this Court.” Id. at *7. Previous courts within the
Sixth Circuit have found that these types of arguments lack merit.
See Clinton v. Coyaleski, No. 4:25-cv-1363, 2025 U.S. Dist. LEXIS
186480, 2025 WL 2711413 (N.D. Ohio Sept. 23, 2025) (collecting
cases that reject jurisdictional arguments based on similar sovereign
citizen arguments), Watts v. Cleveland Heights, No. 1: 25 CV 1582,
2025 U.S. Dist. LEXIS 176338, 2025 WL 2615846 (N.D. Ohio
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Sept. 10, 2025) (finding Defendant’s arguments claiming that that
he was not subject to traffic laws, similar to those advanced in the
filings, as being “devoid of merit”), and Burks v. Licking Cnty. Child
Support Enf’t Agency, No. 2:24-cv-2330, 2025 U.S. Dist. LEXIS
31341, 2025 WL 580389 (S.D. Ohio Feb. 21, 2025) (describing the
voluminous 	filings 	related 	to 	sovereign 	citizen 	arguments 	as
frivolous and wasteful of court resources).
Order Dismissing All Sovereign Citizen Filings at 4. Ms. Kilpatrick’s latest filings
are no less frivolous or wasteful of judicial resources. The VNOI, filed September
2, 2025, had nothing to do with her actual legal obligations and was based on a
complicated 	web 	of 	sovereign 	citizen 	pseudo-legal 	theories 	by 	which 	she
supposedly put the property in a trust in which only her made-up entity could hold
an interest under equity jurisdiction overseen by the Government of God that
apparently operates outside the bounds of this Court’s statutory jurisdiction, but
somehow would require this and other courts to halt the foreclosure action against
her real estate. Obviously, her assertions are without any basis in law or relevance
to the matters that were actually before this Court, prior to dismissal of her case.
Ms. Kilpatrick continued with her Embassy of Living Faith filings from
September 24, 2025 through September 30, 2025 (Docs. 53-77). All told, including
the first two duplicate Ministerial Cover Letter filings to which her VNOI was
attached, she submitted 27 documents, albeit many were duplicates. She does not,
however, appear to specifically reference any of those other filings (other than the
VNOI) in her present Motions.
Order Denying Stay at 10-14 (bold type removed from headings). The Court will not further
belabor the context in which it was discussing Ms. Kilpatrick’s filings containing sovereign citizen
theories, but suffice it to say that it was in the context of examining the papers she chose to file
with the Court.
2. 	Allegedly Disparaging Language
As shown above, Ms. Kilpatrick’s efforts to cherry pick language out of context in support
of her baseless assertions of bias or prejudice are not well-founded. A review of Ms. Kilpatrick’s
other specific complaints confirms the points above. Ms. Kilpatrick raises four comments that she
insists have “mocking and disparaging language directed at Movant, an in propria personal
litigant[.]” Id. ¶ 8, at 3.
Specifically, Ms. Kilpatrick takes umbrage with the Court referring to Ms. Kilpatrick’s
legal arguments as “peeking down into the rabbit hole.” Id. ¶ 8.a., at 3. That phrase was included
in a footnote in the following context:
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Although the VNOI is clearly a made-up sovereign citizen document with
no legal significance, at the risk of peeking down into the rabbit hole, there is no
possibility of Ms. Kilpatrick having unilaterally created a lien interest in 108
Barnside Drive superior to the Mortgagee’s interest (or the Montgomery County
Treasurer’s) without their agreement. Moreover, the doctrine of merger would
likely result in any such interest (although there is no such legitimate interest)
simply merging into her ownership interest, such that it would have no impact upon
the mortgage being foreclosed. See, e.g., Shah v. Smith, 908 N.E.2d 983, 986 (Ohio
Ct. App. 2009) (defining doctrine of merger by ownership as providing “that a
servitude may not be impressed upon an estate of another estate when both estates
are owned by the same person” (internal quotations omitted)).
(Doc. 89 at 17, n.4.) This footnote explains how, notwithstanding that Ms. Kilpatrick had espoused
discredited sovereign citizen theories in support of her desired outcome, the Court was looking
beyond that frivolousness and attempting to determine if there were any arguments for relief that
could be supported by existing law. In other words, Ms. Kilpatrick’s filings likely received more
time, attention, and analysis then they probably deserved. Ms. Kilpatrick cannot unilaterally create
a lien in her favor, as the owner, that is superior to a previously recorded mortgage she granted.
The phrase “peeking down into the rabbit hole” in this instance refers to accepting the false
premise, for purposes of argument only, by first pretending that Ms. Kilpatrick’s Verified Notice
of Interest or VNOI had some legal meaning and therefore winding up at a strange place in the
legal analysis. See Kathryn Schulz, The Rabbit-Hole Rabbit Hole, The New Yorker, June 4, 2015,
at 1 (“In its most purely Carrollian sense, then, to fall down a rabbit hole means to stumble into a
bizarre and disorienting alternate reality.”). That remains an apt description of her legal theory.
Ms. Kilpatrick also raises concern with the Court allegedly “[s]arcastically describing
Movant’s trust claims as operating ‘under the Government of God that apparently operates outside
the bounds of this Court’s statutory jurisdiction, but somehow would require this and other courts
to halt the foreclosure action[.]’ ” Recusal Mot. at 3, ¶ 8.b. This is the exact phrase used by Ms.
Kilpatrick; thus, it was not described by this Court. Again, seeing the use of the phrase in context
of the Court’s prior Order Denying Stay, as quoted above, confirms this is true:
The VNOI, filed September 2, 2025, had nothing to do with her actual legal
obligations and was based on a complicated web of sovereign citizen pseudo-legal
theories by which she supposedly put the property in a trust in which only her made-
up entity could hold an interest under equity jurisdiction overseen by the
Government of God that apparently operates outside the bounds of this Court’s
statutory jurisdiction, but somehow would require this and other courts to halt the
foreclosure action against her real estate. Obviously, her assertions are without any
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basis in law or relevance to the matters that were actually before this Court, prior
to dismissal of her case.
Order Denying Stay (Doc. 90) at 14. Ms. Kilpatrick’s twenty-seven (27) Filings to this Court were
all grounded in an entity unknown to this Court, but which is referred to as the “Embassy of Living
Faith.” Id. Ms. Kilpatrick cited to the Old and New Testaments of the Bible and referenced some
separate ecclesiastical jurisdiction that would impact this now-dismissed bankruptcy case. See
Doc. 44 at 1 (now stricken) (“This Ministerial Cover Letter tenders actual and constructive notice
of sacred ecclesiastical instruments under the covering of The Embassy of Living Faith™, a
private ecclesiastical trust estate established and administered under the Government of God.”
(emphasis added)). The Court’s Order simply quoted and described, in the precise terms Ms.
Kilpatrick used in her own filings, the highly unusual assertions and arguments she submitted in
her papers filed with this Court. Thus, it is clear that simply quoting and discussing the assertions
advanced by Ms. Kilpatrick, using the exact same language she used, cannot be reflective of any
bias. Moreover, even if the Court accepted Ms. Kilpatrick’s premise of sarcasm (which is without
any basis in respect to the Court’s use of the terminology included in her filings), that does not
form a basis for recusal. See Liteky, 510 U.S. at 555.
Ms. Kilpatrick additionally objects to the Court describing her filings “as a ‘barrage,’
‘mountain,’ and ‘complicated web.’ ” Recusal Mot. at 3, ¶ 8.c. If she did not want her filings
described as such she should have refrained from filing twenty-seven (27) voluminous frivolous
filings espousing complex sovereign citizen theories outside the bounds of and contrary to existing
law. Again, following the filing of the Motion to Dismiss, Ms. Kilpatrick filed twenty-seven (27)
documents in September 2025, including twenty-five (25) between September 24 and September
30. See Docs. 44-45, 53-77 (since stricken). This amount of filings in a condensed period are quite
extraordinary in a garden-variety consumer chapter 7 bankruptcy case. The use of the words
“mountain” and “barrage” were merely descriptors of the flurry of activity in Ms. Kilpatrick’s case
and do not demonstrate bias under existing case law. Similarly, the Court’s use of “complicated
web” was used to describe Ms. Kilpatrick’s VNOI argument, which relied on the authority of Ms.
Kilpatrick’s “ecclesiastical jurisdiction” as “Living Heir,” titles which the Court has yet to come
across in any existing case law or statute. This description of Ms. Kilpatrick’s filings does not in
any way amount to bias, they are accurate and well-earned descriptions.
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Finally, Ms. Kilpatrick takes issue with the Court “[r]eferring to Movant’s representative
capacity as ‘made-up’ and her interests as ‘self-granted made-up interest[s].’ ” Recusal Mot. at 3,
¶ 8.d. Interestingly, however, yet again Ms. Kilpatrick does not contest the truth of this statement,
but only states that she does not like it. In observing this the Court was specifically referring to her
signature block on the VNOI filed with this Court. In context, “[t]he VNOI was signed by Ms.
Kilpatrick, albeit as ‘the Living Heir in Sacred Honor’ as ‘Marguerite Latete of the House of
Kilpatrick,’ with the titles ‘Beneficial Owner,’ ‘Equitable Titleholder,’ ‘Authorized Agent,’ and
‘Custodian Ambassador for Christ and Minister within The Embassy of Living Faith™.’ ” Order
Denying Stay at 11 (quoting VNOI (Doc. 44-1) at 9). Further, her complaint about this Court’s
accurate characterization about the capacity in which she purported to sign her twenty-seven (27)
Filings is wholly undercut by the fact, as noted in a footnote to the Order Denying Stay, that:
Ms. Kilpatrick has since attempted to cure her prior violations of Bankruptcy Rule
9011(a) through her Notice of Errata Regarding Debtor’s Capacity (Doc. 87), as
filed on October 28, 2025, in which she writes that “Debtor previously submitted
filings that, through clerical oversight, described the filer in a representative or
fiduciary capacity.” Further, she wrote that she “hereby clarifies and affirms that
all current and future filings in this Court are submitted solely in the Debtor’s
personal capacity as the Chapter 7 Debtor, and not in any other representative,
trustee, or managerial capacity.” (Emphasis in original). Moreover, she purports to
“expressly ratif[y] and adopt[] all prior pleadings, motions, and notices as of their
original filing dates.”
Order Denying Stay at 11, n.11. The fact that she attempted to correct the alleged capacities in
which she previously signed those documents is a tacit admission that those capacities were not
real and were frivolous.
The titles from Ms. Kilpatrick’s signature block did not have any recognized legal meaning,
again, being based on sovereign citizen theories, and are thus invented concepts. The words “self-
granted made-up interest” was used to described Ms. Kilpatrick’s attempt to unilaterally create a
lien on her residence superior to her mortgage, which is not possible. In context, the Court said,
“it is also readily apparent that the alleged interest she holds in 108 Barnside Drive, which she
refers to as the ‘trust res,’ is a self-granted made-up interest based on her ‘Embassy of Living
Faith’ strain of sovereign citizen theories.” Order Denying Stay at 11. Ms. Kilpatrick’s capacity
was not created by any recognized law, and thus the Court accurately described it as being
invented. And Ms. Kilpatrick’s subsequent correction confirms this is the case.
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B. 	Alleged Speculative Factual Findings
Second, Ms. Kilpatrick argues that the Court’s perception about Ms. Kilpatrick’s use of
artificial intelligence to draft her filings should be disqualifying. The Court’s concerns stem from
a case cited by Ms. Kilpatrick in her Emergency Motion for Stay, In re Miller, 150 B.R. 834
(Bankr. N.D. Ohio 1993), which the Court determined does not in fact exist. That citation leads to
a page in Brandt v. 440 Assoc., 150 B.R. 833 (Bankr. S.D. Fla. 1993), which is unrelated to the
proposition it was asserted to support in Ms. Kilpatrick’s Emergency Motion for Stay. See Order
Denying Stay, (Doc. 89 at 20-21). “An attempt to persuade a court or oppose an adversary by
relying on fake opinions is an abuse of the adversary system.” Whiting v. City of Athens, Tenn.,
Nos. 24-5918, 24-5919, 25-5424, 2026 U.S. App. LEXIS 7479, at *7 (6th Cir. Mar. 13, 2026)
(citing Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 461 (S.D.N.Y. 2023) and collecting cases).
Parties are expected to verify the case law that they rely on for their arguments, so “citing even a
single fake case can be sanctionable.” Whiting, 2026 U.S. App. 7479, at *8.
The Court truthfully noted that Ms. Kilpatrick referenced a case that did not exist, and that
citations to non-existent case law can be a sanctionable offense. Further, the Court merely stated
that it “may be an AI ‘hallucination,’ ” but did not make any actual findings beyond this regarding
the cause of Ms. Kilpatrick’s citation to non-existent case law. Citations to nonexistent case law
are a violation of Bankruptcy Rule 9011, a rule which applies to all litigants regardless of pro se
status. In re Jones, 632 B.R. 138, 147 (Bankr. S.D. Ohio 2021) (collecting cases). The Court has
announced its intention to allow Ms. Kilpatrick to explain her use of this citation at a future
sanctions hearing; thus, Ms. Kilpatrick’s complaints are premature.
Finally, based on the Court’s experience, her filings have the appearance of being generated
by ChatGPT, such that the Court has questioned whether that is how she came up with a case law
citation that does not exist, which is commonly referred to these days as a “hallucination.” It is
hard to fathom how else she came up with this non-existent case law, or, as a pro se filer, the
number of case law and statutory citations set forth in her filings. Thus, there is already a number
of indicators that her filings were prepared with the aid of artificial intelligence (“AI”); however,
Ms. Kilpatrick is free to testify in open court about how exactly she went about preparing her
filings. Moreover, simply observing what she has filed with the Court is not a bias. And, again, the
Court will hold a hearing before imposing any sanctions, as it has written many times before.
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C. 	Potential Sanctions Proceedings
Ms. Kilpatrick also argues for recusal because she alleges that this Court has predetermined
any outcome of a sanctions hearing. However, it is clear that the Court has yet to make any
decisions on sanctions, has not yet held a hearing on this issue, largely due to her continuing stream
of filings, and will allow Ms. Kilpatrick to appear before the Court prior to any orders on sanctions.
The Court has not made any findings outside of those which are perfectly apparent on the face of
Ms. Kilpatrick’s filings. Bankruptcy Rule 9011 grants a judge inherent authority to, “after notice
and a reasonable opportunity to respond[,]” issue sanctions to aid in managing its own docket and
deterring meritless filings. Fed. R. Bankr. P. 9011(c); Collier on Bankruptcy ¶ 9011.05 (Richard
Levin and Henry J. Sommer, eds. 16th ed.). “[S]anctions are appropriate if a pleading is not
warranted by existing law or a good faith argument for the extension or modification, or reversal
of existing law.” Jones, 632 B.R. at 147 (citing In re Dunn, 320 B.R. 161, 164 (Bankr. S.D. Ohio
2004)). As noted above, citations to nonexistent case law can be a sanctionable offense. Ms.
Kilpatrick notes in her Motion to Recuse that her “legal theories may be unorthodox,” and this
Court believes that they are unorthodox to such an extent that her filings in themselves advance
baseless legal propositions and thus may constitute sanctionable conduct. Recusal Mot. ¶ 21, at 7.
The Court will not, consistent with Bankruptcy Rule 9011(c), impose any sanctions until Ms.
Kilpatrick has had the opportunity to be heard.
Ms. Kilpatrick further argues that the Court’s statements that “‘[p]resuming that [Ms.
Kilpatrick] either does not appear or cannot show cause, the Court may proceed to impose
sanctions,’ demonstrat[es] that the Court has already concluded Movant cannot show cause[.]”
Recusal Mot. at 5, ¶ 12.c. However, the Court uses the word “may” to indicate that sanctions are
conditioned upon both the Court’s judicial discretion and Ms. Kilpatrick either not attending the
sanctions hearing, which would be a violation of the show cause order, or failing to show cause as
to why her filings are not sanctionable. The Court’s belief that Ms. Kilpatrick’s filings may be
sanctionable are not based on any animus or prejudgment towards Ms. Kilpatrick, but rather on
the content of the filings themselves. Though Ms. Kilpatrick may disagree with the Court’s
interpretation of her filings, “unfavorable rulings do not provide a valid basis for recusal.” Carson
v. Merit Sys. Prot. Bd., No. 20-3459, 2021 U.S. App. LEXIS 14691, at *10 (6th Cir. May 17, 2021)
(citing U.S. v. Grinnell Corp., 384 U.S. 563, 583 (1966); Youn v. Track, Inc., 324 F.3d 409, 422-
23 (6th Cir. 2003)). If every judge that elected to hold a hearing regarding a litigant’s sanctionable
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conduct was found to be biased on that basis alone, judges would be forced to play musical chairs
every time they encountered a potential Bankruptcy Rule 9011 violation.
D. 	Potential Vexatious Litigator Designation
Ms. Kilpatrick also argues that the Court’s statement in the Order Denying Stay that “it
may be possible to classify [her] as a vexatious litigator who should no longer be afforded the
opportunity to file any papers with this Court” was made as a “threat” without any notice or
hearing. Recusal Mot. ¶ 14, at 5. However, this prior comment is based on the numerous –
twenty-seven (27) – frivolous Filings she submitted to this Court, even prior to her recent attempt
to open a new adversary proceeding in her closed bankruptcy case based on patently false
allegations that there is a bankruptcy, a bankruptcy estate, and an automatic stay, as addressed in
the Order Rejecting Adversary Proceeding being contemporaneously entered. That is the record in
this case such that the observation is fully earned and warranted. However, as of yet the Court has
not issued an order declaring Ms. Kilpatrick to be a vexatious litigator and has not imposed a
wholesale bar to her filing papers, but rather has dealt with each of her filings and their merits (or
lack thereof) as presented, and has not yet issued any order further acting to protect this Court from
her “ ‘harassing and vexatious pleadings[,]’ ” which would be well within its authority. Ms.
Kilpatrick cannot file numerous frivolous filings with this Court and then act as though nothing
happened. There is no bias here, just a recitation of her documented conduct and filings.
In the big picture, Ms. Kilpatrick has already been barred from filing any further
bankruptcies for at least one (1) year due to her bad faith serial filings and conduct, such that her
subsequent barrage of the twenty-seven (27) Filings, coupled with the recent attempt to file a
frivolous new adversary proceeding in a closed case simply provides further basis to potentially
classify her as a “vexatious litigator” after notice and a hearing. See In re Grp. Mgmt. Corp., No.
03-93031-WLH, 2022 Bankr. LEXIS 3517, at *5-6 (Bankr. N.D. Ga. Dec. 13, 2022); NPF
Franchising v. SY Dawgs, LLC, 37 F. 4th 369, 377 (6th Cir. 2022) (citing Wilson-Simmons v. Lake
Cnty. Sheriff’s Dep’t, 207 F.3d 818, 822 (6th Cir. 2000)). Additionally, imposing vexatious
litigator status upon her would not completely bar her access to the court system, but would instead
place prefiling restrictions on any future filings, which is effectively what this Court has already
done in barring her from filing further bankruptcies. Feathers v. Chevron U.S.A., 141 F.3d 264,
269 (6th Cir. 1998). But the Court has not yet done this; rather, contemporaneously with ruling on
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her Motion to Recuse it declined to open a new adversary proceeding based on her submitted
Complaint on the basis that there is no subject matter jurisdiction for this Court to hear the
Complaint in a dismissed bankruptcy case in which there is no bankruptcy estate and no automatic
stay. As before, the Court has fully considered and issued a thoroughly considered ruling on her
filings, even though the Court has ultimately determined the filing is frivolous.
This Court, over seven months ago, alerted Ms. Kilpatrick to the fact that her twenty-seven
(27) Filings lacked any merit and should be withdrawn, in the Order Denying All Filings (Doc.
78) entered on October 1, 2025. She did not withdraw her Filings. Instead, she then filed her
Emergency Motion for Stay and Motion to Withdraw the Reference, filed her Motion for
Reconsideration, and then filed her Motion to Recuse, all in an effort to avoid any consequence
for her conduct in barraging this Court with the sovereign citizen Filings, but only exacerbating
the issue in the meantime. As previously noted, the Court has addressed each in turn, on the basis
of the assertions therein, such that the Court has not further restricted her access to filing beyond
the one (1) year bar already imposed. As promised, the Court will schedule a hearing before
determining whether to impose any sanctions, which could include labeling her as a vexatious
litigant. But as of yet the Court has not done so, and she will have a full and fair opportunity to
attempt to explain why she should not be so labeled.
E. 	Judicial Oath (28 U.S.C. § 453)
Finally, Ms. Kilpatrick argues that this Bankruptcy Judge has violated his judicial oath
under 28 U.S.C. § 453. However, Ms. Kilpatrick does not provide any specific examples of how
this Judge has violated his oath other than the unfounded complaints that have already been
discussed above. She does not explain how those complaints translate into a failure to “administer
justice . . . faithfully and impartially[.]” 28 U.S.C. § 453. The Court takes very seriously its “duty
. . . to see that the laws of the United States Bankruptcy Code are enforced[,]” and the Court’s
actions in this case have been fully in accordance with that duty. Miami Emp. Fed. Credit Union
v. Turner (In re Turner), 69 B.R. 95, 96 (Bankr. S.D. Ohio 1987). Again, the Court has spent
significant time and effort to carefully examine all of Ms. Kilpatrick’s Filings to ensure that it
appropriately construed and considered whether those Filings stated any claims for relief based on
existing applicable law. If anything, because the Court takes its oath so seriously, it probably spent
too much time on her twenty-seven (27) Filings that, in retrospect, were a misguided effort through
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use of sovereign citizen theories to avoid the inevitable foreclosure of her real property, which was
similarly the basis upon which the U.S. Trustee filed his Motion to Dismiss that was unopposed
by Ms. Kilpatrick and granted. Further, the Court has only retained limited “clean up” jurisdiction
over the potential issue of sanctioning Ms. Kilpatrick under Bankruptcy Rule 9011 because she is
not by any means the only person to who justice needs to be administered. The Court must employ
the tools available to it to protect its resources and ensure filings before it are appropriate, so that
it can equitably administer justice. Few, if any, other litigants in the Court’s tenure so far have
filed as many papers without a legitimate legal basis, yet the Court has given every filing due
consideration before reaching any conclusions as it will continue to do so.
VI. 	Conclusion
For all the foregoing reasons, the Motion to Recuse (Doc. 101) is hereby DENIED with
prejudice.
IT IS SO ORDERED.
Copies to: Default List
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