## Facts

- Members of the Republic of New Africa (RNA) used a building in Jackson, Mississippi as a “capitol” and conducted regular meetings that included military-style drills.
- The group kept weapons readily accessible inside the building, including an automatic rifle, a fragmentation bomb, and incendiary devices.
- After an undercover FBI investigation and based on arrest warrants for individuals believed to be inside, federal and local officers surrounded the RNA building to execute the warrants.
- When officers attempted to carry out the arrests, an armed confrontation occurred; one officer was killed and two were wounded.
- Weapons connected to the confrontation were not registered as required by federal firearms law.
- A federal grand jury returned a four-count indictment: (1) conspiracy to assault federal officers, use firearms in the assault, and possess unregistered firearms; (2) assault on federal officers with dangerous weapons (as to four defendants); (3) use of firearms to commit that assault (as to the same four); and (4) possession of unregistered firearms (as to James).
- A jury convicted each defendant on all counts charged against that defendant, and the district court imposed cumulative sentences on the defendants convicted of substantive offenses.

## Issues

1. Whether entry into and searches of the RNA building and related seizures violated the Fourth Amendment given the officers’ arrest warrants, belief that wanted persons were inside, and the circumstances confronting officers.
2. Whether the evidence was sufficient to prove the charged conspiracy and the substantive offenses of assaulting federal officers, using firearms during the assault, and possessing unregistered firearms.
3. Whether the RNA’s claimed sovereign or foreign-nation status negated federal jurisdiction or provided a defense to federal criminal prosecution.
4. Whether evidentiary rulings, use of undercover agents/informants, or other trial procedures required reversal.

## Decision

- The Fifth Circuit affirmed all convictions.
- The court held the challenged entry/searches and seizures were reasonable where officers had valid arrest warrants, reasonably believed the subjects were inside, and faced exigent circumstances arising from armed danger.
- The court found sufficient evidence of an agreement to use force, preparation through drills and weapon staging, and actual armed resistance supporting the conspiracy and substantive counts.
- The court rejected arguments that a self-proclaimed alternative sovereignty exempted defendants from federal criminal law or federal jurisdiction.
- The court found no reversible error in the remaining evidentiary and procedural claims.

## Legal Principles

- Officers executing valid arrest warrants may enter premises when they reasonably believe the warrant subjects are inside; dangerous, rapidly developing conditions can supply exigent circumstances supporting immediate entry and related seizures.
- Conspiracy may be proved by circumstantial evidence, including coordinated preparations, access to weapons, statements reflecting intent, and conduct consistent with a shared unlawful objective.
- Evidence of organizational drills, weapon storage practices, and rhetoric about violent resistance can be admissible to show intent, agreement, and foreseeability of armed confrontation.
- Claims of sovereignty by a private group do not bar enforcement of federal criminal statutes or defeat federal jurisdiction over crimes against federal officers and federal firearms offenses.

## Conclusion

The Fifth Circuit upheld convictions arising from an armed confrontation during execution of arrest warrants at an organization’s headquarters, concluding the officers’ entry and seizures were justified by reasonable belief and exigent danger, the evidence supported the conspiracy and firearms-related offenses, and a self-declared sovereign status did not immunize defendants from federal prosecution.


United States v. James, 528 F.2d 999 (5th Cir. 1976)