White supremacist groups probably took some sordid pride when they discovered that California prison inmates with Bloods’ and/or Crips’ gang affiliations had adopted their “Sovereign Citizen” movement tactics involving the “UCC-1 (Uniform Commercial Code, hereinafter UCC) bogus lien filing scam.” These tactics were developed in the 1960s as part of an anti-government secessionist agenda to undermine government prosecutions and tax enforcement as well as the harassment, intimidation, and retaliation against public officials.

It took about 50 years for the UCC-1 bogus lien filing scam that started in isolated jails in Alaska to move across the nation from California and reach the East coast and then about five years to become fully operational in New York state. And like any bad idea that communicates through word of mouth and criminal conspiracies, the scam morphed as it spanned the nation. With the help of the digital era and individual Internet access, it now has resurrected in the post-2009 quagmire of the foreclosure crisis that New York courts confront today. This article will address the latest metamorphoses of the bogus UCC-1 notice of lien filing scam, its impact on the courts and remedies in New York.

Prison Practices