Bankr. W.D.N.C.: In re Ford (II) — Court Rejects “Tribal Sovereignty” Claims, Denies Recusal, and Increases Sanctions Against Debtor for Pseudo-Legal Defenses
Bankr. W.D.N.C.: In re Ford (II) — Court Rejects “Tribal Sovereignty” Claims, Denies Recusal, and Increases Sanctions Against Debtor for Pseudo-Legal Defenses Ed Boltz Tue, 10/14/2025 - 17:43 Summary: In In re Ryan Lashon Ford, Judge Edwards issued two companion opinions chronicling the court’s escalating efforts to bring order to what she aptly described as an “atypical” pro se Chapter 7 case that had metastasized into a performative exercise in pseudo-law. Background and Procedural History Beginning in December 2024, the debtor filed a barrage of more than two hundred pleadings—motions to dismiss, convert, compel, and “declare tribal property”—along with serial assertions that her assets belonged not to the bankruptcy estate but to the self-styled “Xi Amaru Tribal Government,” a group offering “jurisprudence” courses and “law consultation” to its adherents. When questioned, the debtor could recall neither what she had paid for these courses nor basic details about her bank accounts, transfers, or tenants. The Chapter 7 Trustee and Bankruptcy Administrator sought routine discovery into these transfers and the “course materials” that appeared to be generating her pleadings. Despite multiple continuances, explicit directives, and an Omnibus Order requiring production of bank and course records, the debtor refused—citing non-existent federal statutes, fabricated tribal immunity, and even copyright restrictions. The court entered a civil-contempt order with daily sanctions and, after continued defiance, increased the fine to $150 per day. The July 2025 Opinion ( In re Ford I) The earlier opinion had already sanctioned the debtor for contempt after repeated failures to comply with discovery orders. The court recounted her pattern of evasive testimony, including claims that production of the “tribal coursework” would violate “15 U.S.C. § 114”—a statute that, as the court dryly noted, “does not exist.” The decision catalogued her shifting explanations and concluded that her refusal to comply was deliberate bad faith warranting escalating sanctions. The September 2025 Opinion ( In re Ford II) The latest decision addressed the debtor’s “Amended Motion for Recusal” seeking removal of both the Trustee and the Bankruptcy Administrator. Judge Edwards patiently—but firmly—reiterated that (1) the Trustee’s duties under § 704 run to the estate and creditors, not to the debtor; and (2) both the Trustee and Bankruptcy Administrator are statutorily required to investigate omissions, object to improper claims, and ensure orderly administration. Finding no factual basis for bias or misconduct, the court emphasized that adverseness to the debtor is not only permissible but inherent in those fiduciary roles. The debtor’s filing of a state-bar grievance against the Trustee, moreover, was itself prohibited under the Barton Doctrine and the automatic stay—echoing In re Seertech Corp. (W.D.N.C. 2007)—and could not be wielded to create the very “conflict” she alleged. Judge Edwards then dismantled the debtor’s claims of “tribal” privilege and bias. Analogies drawn by the Trustee and Administrator between the debtor’s filings and the sovereign-citizen movement, she wrote, did not equate recognized tribal sovereignty with pseudo-legal theories; they merely illustrated that unrecognized assertions of sovereignty cannot nullify federal law. “[A]nalogies,” she observed, “are a bridge, not a mirror.” Commentary: This pair of orders, in what (given the persistence of sovereign citizens) might eventually be termed the Ford Trilogy, underscores Judge Edwards’ measured but increasingly direct confrontation with the growing sovereign-citizen phenomenon in bankruptcy. As noted in commentary previously circulated to the bankruptcy bar on August 5, 2025 (but withheld from public posting to avoid inflaming a sovereign citizen), I wrote that: While Judge Edwards rightly imposed sanctions and attempted to bring order to the case, it is fair to question whether the court's extended engagement with the debtor’s pseudo-legal defenses gave undeserved credence to what is, ultimately, sovereign-citizen nonsense. By parsing phantom statutes and issuing repeated compliance orders, the court risked signaling that these filings were defective pleadings rather than fantasies. Yet, with these later opinions, Judge Edwards appears to have reached the same conclusion—drawing a bright doctrinal line between legitimate procedural patience and indulgence of performative obstruction. The opinions now serve as a practical template for future cases: a record of escalating judicial responses—from explanation, to order, to contempt, to sanctions—culminating in a clear reaffirmation that bankruptcy courts are courts of law, not forums for tribal mythos or AI-generated “jurisprudence.” More decisive early action—whether through dismissal under § 707(a) for bad faith, denial of discharge under § 727(a)(4) for false oaths, or referral for unauthorized practice—could conserve judicial resources and deter the cottage industry of “sovereignty educators” peddling this nonsense to vulnerable debtors. With proper attribution, please share this post. To read a copy of the transcript, please see: Blog comments Attachment Document in_re_ford_ii.pdf (616.9 KB) Document in_re_ford_i.pdf (481.9 KB) Category Western District
