Child custody action; Paternity & child support; MCL 722.717(1)(c); Personal jurisdiction; MCR 2.105(K)(1); Process; MCR 2.105(A) & (J)(1); The sovereign citizen movement

The court held that the trial court did not err by adopting the interim orders of support following a hearing on defendant-father’s objections to the judgment of support and uniform child support order previously entered as interim orders. Defendant’s paternity was established when he failed to answer plaintiff-mother’s complaint seeking to establish paternity. He subsequently entered objections, claiming the trial court established jurisdiction over a legal entity instead of his true person. The trial court dismissed his objections and entered an order adopting both the interim judgment of support order and the uniform child support order. On appeal, the court rejected his argument that the trial court erred when it dismissed his objections and entered the order because it failed to establish personal jurisdiction over him. It noted “plaintiff made multiple attempts to serve defendant personally.” Eventually a “court officer successfully served ‘a copy of the summons and complaint and order for alternate service upon Alvis Perry’ by ‘[t]acking or firmly affixing [the documents] to [defendant’s] door.’” As such, “defendant was properly served the summons and complaint under MCR 2.105(J)(1), and consequently, the trial court appropriately exercised personal jurisdiction over” him. The court also found “defendant’s argument concerning his position as a ‘freeman’ and ‘sovereign citizen’” unpersuasive, noting he attempted “to skirt the trial court’s jurisdiction under the guise of ‘Alvis Perry’ being a fictious legal entity. The sovereign citizen movement attempts to create a distinction between ‘natural’ and ‘artificial’ persons.” Federal courts have also dismissed such claims “as frivolous and fictitious.” Defendant presented “a sovereign-citizen style argument. In his objections to the trial court’s interim orders regarding paternity and child support, [he referred] to himself as ‘[I,] a freeman known to use the name Eleyah-Ben: Avadliel-El, In the Interest of ALVIS EUGENE PERRY – LEGAL ENTITY.’” In his brief on appeal, he similarly referred “to himself as ‘Eleyah-Ben: Avadliel-El on behalf of the legal entity/persona known as ALVIS PERRY.’” This argument, “that he is a distinct person or entity from ‘Alvis Perry,’ lacks legal merit and is a fictitious argument. Thus, we agree with the trial court that defendant’s objections ‘contain no legally cognizable claim.’” Affirmed.