The recent Chicago federal criminal trial of Cherron Phillips, a.k.a. “River Tali El Bey” has shed some public light on the “sovereign citizen” movement and their insidious practice of “paper terrorism” of filing false liens against public officials, judges, police officers, corporations and banks. Ms. Phillips was convicted of ten counts of retaliation for filing billions of dollars in false liens against public officials. While her trial has been widely reported in Illinois, the underlying issue of paper terrorism is unfortunately not new, and government bodies, banks, and public interest groups have been grappling with this issue for many years. Last year, the Illinois Appellate Court and the Illinois State Legislature started to fight back against these tactics.