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  • Judge Julie S. Sneed
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Smart Summary

Factual and Procedural Background

On April 3, 2026, the Court received a document from Ms. Atwood, who identified herself as the “general executor for Cary Lyn Atwood Estate.” The Clerk assigned the filing a miscellaneous case number and closed the matter. Ms. Atwood continued submitting similar documents, including filings asserting that her name has copyright and trademark protection. [1]

Ms. Atwood also filed complaints in two other cases and appeared to be using the miscellaneous-case filings to establish facts supporting those allegations. [2]

Legal Issues Presented

  1. Whether Ms. Atwood’s filings constituted pleadings under Federal Rule of Civil Procedure 8(a) or stated a claim and jurisdictional basis. [3]
  2. Whether the Court should prevent further filings in the miscellaneous matter and warn of potential sanctions. [4]

Arguments of the Parties

The opinion does not contain a detailed account of the parties' legal arguments.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Gravatt v. United States, 100 Fed. Cl. 279, 282 (2011) Description of sovereign-citizen beliefs and tactics. The Court used the case to explain the nature of the filings it characterized as sovereign-citizen filings. [5]
Henry v. Hernandez-Rundle, 773 F. App’x 596, 597 (11th Cir. 2019) Sovereign-citizen claims have no arguable legal basis and are patently frivolous. The Court cited the decision in support of its conclusion that the filings were frivolous. [2][6]
Pettingell v. Rolle, No. 1:26cv49-TKW-HTC, 2026 WL 1067390, at *1 (N.D. Fla. Mar. 20, 2026), report and recommendation adopted by 2026 WL 1050228 (N.D. Fla. Apr. 17, 2026) Sovereign-citizen arguments challenging jurisdiction have been universally rejected as frivolous. The Court cited the decision as additional authority for treating the filings as frivolous. [6]
Fitzgerald v. Mercedes-Benz Financial Services USA, LLC, No. 3:22-cv-1053-MMH-PDB, 2024 WL 3377743, at *5 (M.D. Fla. July 11, 2024) Arguments based on sovereign-citizen ideology are frivolous. The Court relied on this authority to support its characterization of Ms. Atwood’s arguments. [6]
Banks v. Pompeo, No. 2:19-cv-755-FtM-29NPM, 2019 WL 11477403, at *2 (M.D. Fla. Dec. 11, 2019), report and recommendation adopted by 2019 WL 11478072 (M.D. Fla. Dec. 30, 2019) Sovereign-citizen arguments are routinely dismissed as frivolous. The Court cited the decision as further support for rejecting the filings. [6]

Court's Reasoning and Analysis

The Court determined that Ms. Atwood’s filings were not remotely pleadings under Federal Rule of Civil Procedure 8(a) because they stated neither a claim nor a basis for the Court’s jurisdiction. [3]

The Court further found that using filings in this miscellaneous matter to establish facts for separate complaints was wholly improper. [2]

Characterizing the filings as sovereign-citizen filings, the Court concluded that they were frivolous, relying on decisions rejecting such arguments as lacking an arguable legal basis and as improper challenges to jurisdiction. [2][6]

Because Ms. Atwood continued submitting similar documents after the matter had been closed, the Court directed the Clerk to stop accepting filings in the matter and cautioned her that continued attempts could result in sanctions. [1][4]

Holding and Implications

The Clerk was directed to no longer accept filings in this matter. Ms. Atwood was cautioned that continuing to file documents could subject her to sanctions. [4]

The direct effect was to terminate further filing activity in the miscellaneous matter and warn the plaintiff of potential sanctions. The opinion did not establish any new precedent.

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Cary Lyn Atwood Estate v. United States

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA

OCALA DIVISION

CARY LYN ATWOOD ESTATE,

Plaintiff,

v. Case No.: 5:26-mc-00004-JSS-PRL

UNITED STATES OF AMERICA,

Defendant,

/

ORDER

On April 3, 2026, the Court received a nonsensical document from Ms. Atwood, who apparently refers to herself as the "general executor for Cary Lyn Atwood Estate." The Clerk received this filing, assigned it a miscellaneous case number, and then appropriately closed the matter. Unfortunately, Ms. Atwood, who also claims that her name has some copyright and trademark protection, continues to file similar nonsensical documents in this miscellaneous matter.

Her filings are not even remotely close to pleadings under Federal Rule of Civil Procedure 8(a). She states no claim or basis for the court's jurisdiction to entertain these documents.

She has, however, filed complaints in other cases (5:26-cv-00588-WWB-PRL and 5:26- cv-00589-CEM-PRL), and it appears that she is attempting to use the filings she keeps submitting here to establish "facts" to support her allegations in those cases. This is wholly improper. Her "sovereign citizen"1filings are frivolous. See, e.g., Henry v. Hernandez-Rundle,

1 In simple terms, sovereign citizens believe that they are not subject to government authority and employ various tactics to avoid paying taxes, extinguishing debts, and derailing criminal proceedings. Gravatt v. United States, 100 Fed. Cl. 279, 282 (2011).

1

773 F. App'x 596, 597 (11th Cir. 2019) (finding that sovereign citizen "claims have no arguable legal basis and are patently frivolous"); Pettingell v. Rolle, No. 1:26cv49-TKW-HTC, 2026 WL 1067390, at *1 (N.D. Fla. Mar. 20, 2026) ("The 'sovereign citizen' argument challenging the Court's jurisdiction has been universally rejected as frivolous."), report and recommendation adopted by 2026 WL 1050228 (N.D. Fla. Apr. 17, 2026); Fitzgerald v. Mercedes- Benz Financial Services USA, LLC, No. 3:22-cv-1053-MMH-PDB, 2024 WL 3377743, at *5 (M.D. Fla. July 11, 2024) (finding that plaintiff's arguments based on "sovereign citizen ideology" were frivolous); Banks v. Pompeo, No. 2:19-cv-755-FtM-29NPM, 2019 WL 11477403, at *2 (M.D. Fla. Dec. 11, 2019) (recommending dismissal of plaintiff's claims since they "appear[ed similar to the sovereign citizen arguments that courts have routinely dismissed as frivolous"), report and recommendation adopted by 2019 WL 11478072 (M.D. Fla. Dec. 30, 2019).

The Clerk is directed to no longer accept filings in this matter. Plaintiff is cautioned that she may be subject to sanctions if she continues to attempt to file documents in this matter.

DONE and ORDERED on August 28, 2026. Copies furnished to:

Counsel of Record

Unrepresented Party

2

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Cary Lyn Atwood Estate v. United States
(Aug 28, 2026)