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E.D.N.C.: Macedon v. North Carolina- Dismissal of Sovereign Citizen Action Challenging Foreclosure

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By Ed Boltz, 21 April, 2025

Summary:

In this foreclosure-related action, the district court  dismissed with prejudice a pro se complaint challenging a completed non-judicial foreclosure under a mélange of constitutional, statutory, and sovereignty-based theories.      

The court applied the Rooker-Feldman doctrine to bar the borrower’s attempt to unwind a state-court authorized foreclosure order, underscoring that federal courts nearly always  lack jurisdiction to review or reverse state court foreclosure rulings.     The court also found that assistant clerks acting in their judicial capacities—here, approving a foreclosure—are immune from suit as individuals, being  shielded by Eleventh Amendment sovereign immunity.   The  Plaintiff’s complaint was also dismissed for numerous defects: lack of jurisdiction, failure to state a claim, and incomprehensible legal theories. 

Commentary:

This is not the end of this case,  as it has been (as is  de rigueur for sovereign citizen lawsuits)  appealed to the Fourth Circuit Court of Appeals.  At least the complaint wasn't signed with a bloody thumbprint.

With proper attribution,  please share this post. 

To read a copy of the transcript, please see:

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macedon_v._north_carolina.pdf (285.04 KB)
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Eastern District

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