Sinkfield v. Guterres

Background

Deon Sinkfield, Jr. filed multiple documents, including at least three that appeared to be complaints. The court treated ECF No. 11, titled the “Second Amended Complaint,” as the operative pleading. The court explained that although Sinkfield had no automatic right to amend a second time, it would treat that filing as operative because the federal rules favor allowing amendments when justice requires.

The pleading named four “Respondents”: Antonio Guterres, identified as Secretary-General of the United Nations; Donald Trump, identified as President of the United States; “Lloyd of London Maritime/Marine Company,” which the court said was likely Lloyd’s of London; and John Neal, identified as Lloyd’s chief executive officer.

The court understood Sinkfield to be suing on behalf of himself and a proposed class of “Afro-Indigenous” people. The pleading alleged that the defendants, together with other corporate and religious actors, had profited from a global network of “slave-trust” contracts. According to the court’s description, Sinkfield claimed that the alleged network converted birth-certificate data into secret securities, used those securities as collateral for public debt, and deprived people of tribal sovereignty and property rights.

Sinkfield said he sent the defendants a “Truth Affidavit” in May 2025 and argued that their failure to acknowledge it amounted to a default. He alleged violations of constitutional amendments, federal trust statutes, and international law. He requested cancellation of certain contracts, recognition of his self-declared Afro-Indigenous nation under the 1933 Montevideo Convention, and $312 trillion in “rent” restitution.

Court’s analysis

Sinkfield did not pay the filing fee and submitted a document asserting that he owed no fee. The court treated that document as a request to proceed without paying the fee. Under 28 U.S.C. § 1915(e)(2), a court must dismiss a case proceeding under that statute if it determines that the action is frivolous. The court explained that a claim is frivolous when it lacks an arguable basis in law or fact, including when it rests on an indisputably meritless legal theory.

The court found the action frivolous “from start to finish.” It said the central claim—that the defendants’ failure to respond to Sinkfield’s document created a new sovereign nation owed $312 trillion—had no plausible basis. The court also said the pleading relied on “classic sovereign-citizen theories” that courts in the District of Minnesota had repeatedly dismissed as frivolous.

Disposition

The court dismissed the action without prejudice as frivolous under 28 U.S.C. § 1915(e)(2). It denied Sinkfield’s request to proceed without paying the filing fee as moot because of the dismissal.