The Sovereigns are Coming to Court.

What swayed South Carolina’s conservative Supreme Court to intervene in a capital case involving the death of two police officers?

The accused murderer’s false belief that he is immune from the law may end up actually saving his life.

“Sovereign citizen” is an amalgamated term for roughly 300,000 people who do not recognize U.S. law as the rest of us see it. It’s a group of people as diverse as the country, from white nationalists to black separatists, the Bundy family in the Pacific Northwest to Moorish communities in the South, and from urban cities like Chicago and Milwaukee to rural Abbeville, South Carolina, where Steven Bixby and his parents had their deadly standoff with police in 2003.

Sovereigns don’t just believe they have a get-out-of-jail-free card. They think it’s a violation of their rights whenever an official acting on behalf of the law inquires after them, regardless of whether they have, in fact, broken the law. Sovereigns can’t break the law because, whether it’s speeding down the highway, never paying taxes, or shooting a cop, they believe they’re immune from it.

Their theories arguably cross the boundary of what a reasonable observer would call sane. Some sovereigns believe in every theory, while others believe in bits and pieces. Their core theories originate from a myriad of points, including before the nation’s founding – for instance, one is that Moors, traveling from West Africa, got here first – or at the nation’s founding itself: The framers actually signed two Constitutions, one for the ‘United States’ and another for the ‘United States of America.’ Others commonly reference the replacement of the gold standard in 1933, a Moroccan-American Treaty of Peace & Friendship, the 1879 Posse Comitatus Law, or the Bible.

“The first time I had [a sovereign] in court, I was astounded. I said, ‘Excuse my French, but are you friggin’ kidding me? What are you talking about?’” a retired South Carolina judge told Court Watch. 

Other sovereign theories are more innocent and from a place of ignorance. “It’s like if you went to a law library and just started opening books and reading cases until you found a case or a law that said something you wanted it to say,” one public defender said to Court Watch. “You can find cases to say all kinds of things you want them to say. Maybe you find an Illinois State case that says something. Or you find a New York Federal case. Or maybe you pull something out of dissenting opinion. None of this helps you in South Carolina.” “They’ll find stuff, but they have no clue how to read it,” according to the public defender.

The theories catch on when sovereigns frustrate an already resource-stretched system. “Let’s say you have a traffic court,” the public defender said, “and you have a judge, prosecutor, and a cop trying to move over a hundred cases a day. The most you’re looking at in a [traffic] court is maybe a 30-day offense. So, you get these crazy people who come in and demand all of these documents, motions hearings, and continuances after continuances. What is the court going to do a lot of times? Screw it, dismiss. And then they dismiss the case, which leads people to believe that this stuff works. If I tell a client, ‘Your charge got dismissed because you’re being a pain in the butt.’ All the client hears is, ‘Yeah, because my arguments worked.’”

Some sovereigns are reactive, making nonsensical arguments when their legal situation becomes precarious. According to another public defender, sovereigns tend not to “just run out and hit people, and say, ‘Haha. You can’t catch me. I’m immune.’ It’s when provoked, and then things can get out of hand because there’s a fundamental disagreement over whether a police officer or a judge has the authority to talk to you.” 

Those disagreements can turn deadly. In 2010, a sovereign father and his 16-year-old son killed two officers in Memphis when a traffic stop went wrong. Law enforcement eventually surrounded and killed them both. An Alaskan sovereign killed two state troopers in 2014 when they arrived at his house to arrest his father. In October 2024, a man who held sovereign beliefs was killed in Florida when police tried to arrest him for failure to appear in court on a trespassing charge. Video from an officer’s body-worn camera showed escalating tensions over the conflict between the police’s lawful and the man’s sovereign commands, each existing in entirely separate legal universes.

On December 8, 2003, Steven Bixby and his seventy-four-year-old dad, Arthur Bixby, shot and killed Abbeville County Sheriff’s Deputy Danny Wilson and Constable Donnie Ouzts. Wilson had responded to the Bixby’s house after workers with the State’s Department of Transportation called in fear for their lives. Steven, Arthur, and the mother, Rita, had feuded with the State’s Department of Transportation for weeks about plans to expand an adjacent roadway onto a portion of the Bixby’s property, using ominous language about their willingness to defend it. When Wilson knocked on their door, Bixby fired through it and then dragged him inside with Arthur’s help, where Bixby Mirandized and handcuffed Wilson, who fatally bled out. Ouzts was killed shortly after as the second responding officer. The Bixbys eventually surrendered after trading gunfire for thirteen hours with law enforcement.

At his arraignment, Bixby appeared unrepentant, going on a diatribe about how they had acted in self-defense, quoting loosely connected federal statutes and New Hampshire’s state constitution (where the family resided before SC). He told the court, “If we can’t be any freer than that in this country, I’d rather die.” Arthur and Rita were also charged with murder and as accomplices. The State later could not try Arthur because he had developed dementia. In 2011, Arthur and Rita died a week apart in separate state-run institutions.

Bixby’s defense team tried to minimize his role in the shooting relative to Arthur and Rita for his 2007 trial. The prosecution, in turn, introduced evidence from the killings and letters written by Bixby in jail in which he defended his actions, signing each as “Chaotic Patriot Steve.” The jury quickly found him guilty. At the penalty phase, the defense called Rita, who argued the same anti-government ideology on the stand, and a state psychiatrist. The psychiatrist, however, undercut the defense’s case when he affirmed his assessment of Bixby as rational and competent. After deliberating an hour, the jury recommended a death sentence for each murder, which the judge accepted.

South Carolina’s Supreme Court upheld the conviction and sentence in 2010. Federal appeals did shed light on Rita’s and Arthur’s abusive parenting and that he was brainwashed at a young age, forced to read right-wing literature and the U.S. Constitution, sometimes around the clock. Eventually, Bixby exhausted his federal appeals as well. As executions began again in South Carolina, his legal team hired another psychiatrist to reevaluate Bixby last spring.

The psychiatrist’s report concluded Bixby does not have “sufficient capacity or ability to rationally communicate” with his defense and, therefore, cannot be executed under South Carolina’s competency standards. The psychiatrist diagnosed Bixby with narcissistic and paranoid personality disorders, noting his beliefs that death row inmates were “traded like hogs on the stock market,” how he was adamant that his clothing from the shooting contained traces of Jesus’ DNA, and that there is photographic evidence from the crime scene showing an angel was present. 

Yet, the reason why the psychiatrist determined Bixby could not meaningfully participate in his defense was his “sovereign citizen,” “bizarre[,] and inaccurate beliefs about the legal system,” which make it “impossible” for him to understand the evidence against him and why the shootout in 2003 was wrong. The report states Bixby brought a copy of New Hampshire’s Constitution to each of their sessions, vowing the “truth” would come out. Bixby reportedly claimed that the police department was an unconstitutional “standing army,” that amendments following the Tenth Amendment were unconstitutional, and that his death warrant was “null and void” because it was not “properly sworn and completed.” The psychiatrist wrote he was adamant about waiting for a court with the right jurisdiction to overturn his sentence.

On November 27, 2024, Bixby’s defense team filed separate motions with Abbeville’s General Sessions and South Carolina’s Supreme Court for a new post-conviction hearing and stay of execution in light of the psychiatrist’s findings. For four months, the docket showed little activity as the Court issued death warrants for other condemned men. Then, the Court, in a 3-2 decision on March 14th, 2025, abruptly granted a stay and ordered a hearing for post-conviction relief. 

Many of the most notorious sovereign citizens were so far gone that they believed they needed to take matters into their own hands against the government. That group includes Terry Nichols, currently incarcerated in ADX Florence for helping Oklahoma City bomber Timothy McVeigh and former Congresswoman Gabrielle Gifford’s attempted assassin. Bixby’s attorneys will argue that he was too far down the rabbit hole – both at the time of the shootout in 2003 and now – from society's moral and legal realities to be executed.

Bixby’s case is not analogous to every sovereign ensnared in the legal system. From Court Watch’s review, Bixby is one of the few sovereigns on death row, and though sovereigns have a history of violence, he is still an extreme example. Yet, Bixby highlights the people who live in separate legal realities and in between, who mix the real with the misinformed. It is a group likely to grow as society and stakeholders struggle to put safeguards on the information space. As one federal public defender pointed out, the top bestseller in Amazon’s “juries” category is a handbook for sovereigns. Recently, users on X (formerly Twitter) noticed sovereign-esque advertisements promising to teach how to “never pay taxes.” 

In speaking with defense attorneys, judges, and prosecutors, Court Watch heard cases of people who fell victim to sovereign ideology because their circumstances – particularly lack of economic opportunity – taught them to expect less from resources that seemingly exist for others and to seek solutions on their own. Court Watch also learned of cases pushing back against that narrative, including a suburban dentist, a former college basketball player, and a police officer’s wife.

Legal professionals, particularly defense attorneys and judges, should be watchful for sovereign ideology. More than that, though, the legal community needs a comprehensive plan to contain and address sovereign ideology in litigants as the firehose of modern misinformation upends people’s perception of what’s true. Without a plan, cases like Bixby’s and of other sovereigns will become more common, further straining the legal system’s resources and leading more to question the rule of law’s sanctity.

A judge is still weighing Bixby’s attorneys’ claims to decide if he is competent enough to be put to death in South Carolina.