Miyuki Maureen Johnson, appearing pro se, filed nine substantially similar civil actions in the District Court for the District of South Carolina against eight private creditors and one municipal water utility. The disputes arose from debt collection efforts by the defendants. In each case, Johnson alleged that she had created a specific trust, assigned encumbered assets to that trust, and sent the defendants documents purportedly discharging her financial obligations. When the defendants did not accept these submissions or cease debt enforcement, Johnson sought monetary and injunctive relief. The district court accepted magistrate judge recommendations and dismissed all actions as frivolous. Johnson appealed these dismissals, consolidating the appeals before the Fourth Circuit.
The Fourth Circuit, in an unpublished per curiam opinion, conducted an independent review of the records and found no reversible error in the district court's decisions. The court reasoned that Johnson failed to demonstrate the existence of any lawful trust, a prerequisite for her claims. Furthermore, the court held that even if a valid trust existed, Johnson could not proceed pro se on its behalf. The court explicitly determined that Johnson's claims were frivolous because they relied on a sovereign citizen theory designed to avoid debt repayment. The opinion states, 'We have reviewed the records and find no reversible error.' The court concluded that Johnson failed to present any nonfrivolous bases for relief, necessitating the affirmation of the lower court's orders.
The dismissal orders against all defendants in the consolidated cases remain in full force. Johnson's motion to supplement the record was denied, and her appeals were rejected. The decision reinforces that sovereign citizen theories used to discharge debt obligations are legally meritless and that litigants cannot proceed pro se on behalf of non-existent trusts. No remand instructions were issued as the case was affirmed.