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1 Willie-Anthony: Brown

c/o 5824 Ludlow St


2 Philadelphia, PA. 19139
856-295-1041 |
3 Tfawgz45jr@gmail.com

5 COMMONWEALTH COURT OF PENNSYLVANIA

7 Willie-Anthony: Brown CP-51-CR-0006768-2022

8 Petitioner,

9 vs. PETITION FOR JUDICIAL REVIEW


CHAPTER 15 RULE 1501
10 COMMON PLEAS COURT OF PHILADELPHIA, NOTICE AND DEMAND TO DISMISS
CORAM NON JUDICE
11 MICHELLE HANGLEY; ET AL, LACK OF IN PERSONAM JURISDICTION

12 Respondent

13

14 Official Notice is hereby served on the COMMON PLEAS COURT OF PHILADELPHIA; all

15 Judicial Sub-Divisions; Officials; Agents; and above-named Petitioner-all cases and All Matters, Complaints,

16 Traffic Tickets / Suits, Citations / Bills of Exchange (misrepresented as lawful warrants, etc.),relating CP-51-CR-

17 0006768-2022 must be Dismissed, pursuant to Jurisdiction named hereinafter.

18

19 COMES NOW, Willie-Anthony: Brown

20 , In Propria Persona, Sui Juris (not to be confused with Pro se), an Aboriginal Indigenous Moorish-

21 American; possessing Free-hold by Inheritance status; Who is here for a special but limited appearance to

22 REQUEST JUDICIAL REVIEW of the following government unit action and or inaction and to demand dismissal

23 of the Order dated 06/23/2023 and signed by Coram Non Judice Judge MICHELLE HANGLEY (Non-Judicial

24 Person)

25

26 Petitioner avers that the above-captioned order is a “nullity” whereas it was offered by a Coram Non

27 Judice or a “Non-Judicial Person” thus it lacks the force of law and is repugnant to Petitioners’ rights as they are

28 PETITION FOR JUDICIAL REVIEWCHAPTER 15 RULE 1501NOTICE AND DEMAND TO DISMISSCORAM


NON JUDICELACK OF IN PERSONAM JURISDICTION - 1
1 enumerated in the Bill of Rights. A State courts assertion of jurisdiction must not violate traditional notions of fair

2 play and substantial justice. To wit State courts are prohibited from making laws that are constitutionally repugnant

4 I. JURISDICTION

6 Jurisdiction / Venue are hereby placed in one Supreme Court, pursuant to Article III Section 2 for The United

7 States Republic, and the several States, under the Constitution; Article VI; and reaffirmed by obligatory Official

8 Oaths.

9 II. PARTIES

10 Respondents

11 1. COMMONWEALTH OF PENNSYLVANIA, private corporation; foreign to the United States Republic;

12 and all CITY OF PHILADELPHIA Employees; Agents; Officers; Contractors; Assignees, etc., being

13 Petitioners, Claimants, or Parties of Interest in the ‘Color-of-Law’ processes instituted by them, or any one of

14 them, against Willie-Anthony: Brown (Hereinafter referred to as “Petitioner”)

15

16 2. Arresting Officer: White, Duane H., of the PHILADELPHIA (private corporation, foreign to the United

17 States Republic; and foreign to the organic Pennsylvania Republic) Officer.

18

19 3. Initial Issuing Authority: Judge MICHELLE HANGLEY, Coram Non Judice, purporting to be a Judge; a

20 private corporation foreign to the United States Republic; and foreign to the organic Pennsylvania Republic.

21

22 4. Petitioner, Willie-Anthony: Brown, In Propria Persona, Sui Juris (not to be confused with Pro se)

23 Aboriginal, Indigenous Moorish American National, C/O 5824 Ludlow st, Philadelphia Territory, Pennsylvania

24 Republic [Postal Zone 19139]ZIP EXEMPT.

25

26

27

28 PETITION FOR JUDICIAL REVIEWCHAPTER 15 RULE 1501NOTICE AND DEMAND TO DISMISSCORAM


NON JUDICELACK OF IN PERSONAM JURISDICTION - 2
1

3 NOTICE AND DEMAND

5 I, Willie-Anthony: Brown, In Propria Persona, Sui Juris; Aboriginal, Indigenous Moorish American

6 National, Freehold by Inheritance with Birthrights and protected and secured Inalienable Rights, makes with

7 this NOTICE AND DEMAND FOR DISMISSAL of the unconstitutional Complaint – Complaint/Citation No.:

8 2219029540-0010325 Petitioner is with reasonable expectation that the Officers / Agents, and Officials,

9 holding any position of Public Trust, or political office, are prohibited, under Official Oath, under the authority

10 of The Law of the Land, from the use of the official position(s) or office(s) to violate the Constitution for the

11 UNITED STATES OF AMERICA; and thus, by the abuse of authority, and the practice of superseding their

12 ‘limited’ jurisdictional powers, violate and abridge the Natural, Divine, Unalienable, and Secured Rights of the

13 People; terminating with the cause of damage to this Petitioner.

14

15 III

16 CAUSE OF ACTION

17

18 1. The Petitioner Willie-Anthony: Brown, while traveling on 60th and Market st in Philadelphia, was detained

19 by Policeman / Prosecuting Witness, Officer White, Duane H .and several others yet to be named;

20 employed by the police department of PHILADELPHIA who stated that WILLIE BROWN was in

21 violation of statute 35 § 780-113which is private policy (being classed as law).

22

23 2. The COMMON PLEAS COURT OF PHILADELPHIA is an unconstitutional, private corporation, not

24 delegated by Congress, under Article III, Section 2 of the Constitution; and that the Officers does not, and

25 did not provide ‘Due Process’ protected and secured for the People, by the Amendments IV, V, VI, VII,

26 VIII, IX, and X of the United States Constitution, to which the Judges and Officers in every State is bound

27

28 PETITION FOR JUDICIAL REVIEWCHAPTER 15 RULE 1501NOTICE AND DEMAND TO DISMISSCORAM


NON JUDICELACK OF IN PERSONAM JURISDICTION - 3
1 (by Official Oath) to support and to uphold. Any statutory regulation, ordinance, or laws of any State, to the

2 contrary, notwithstanding.

4 3. This allegedly - accused Petitioner believes that in accord with the Substantive Rights retained by the

5 Petitioner, notifying all parties of the Petitioner’s Moorish American (Identification / Status) and that the

6 Petitioner was not, is not, and does not, waive any Inalienable Rights to due process; and affirmed that any

7 action be adjudicated in a lawfully delegated jurisdiction and venue.

9 4. The Officers of COURT OF COMMON PLEAS commanded that the Petitioner Pay appear in a Foreign

10 Tribunal of some sort in furtherance of this champertous assault upon petitioners’’ liberty, seeking

11 Imprisonment, Fines and Costs,

12

13 5. Imposed under threat, duress, and coercion with a ‘man-of-straw’ / misnomer word, misrepresented as

14 implying my name, and typed upon the Order / Instrument, and was improperly spelled, “<WILLIE

15 BROWN>” in ALL CAPITAL LETTERS.

16

17 6. That misnomer and CORPORATE - NAME, “WILLIE BROWN” is clearly (an artificial – person /

18 entity); is not me, the Natural Person; is a deliberate grammatical error, intended for injury to me; and is

19 clearly not of consanguine relationship to me or to my nationality, in any form, truth, or manner, nor to my

20 Moorish Family Bloodline.

21

22 7. This is in violation of my secured rights to my name and nationality; a violation of International Law; and

23 a violation of the Obligations of the Officers of the Court of Common Pleas; and a violation of their

24 fiduciary duties and Official Oaths to uphold and to support Article VI of the United States Constitution;

25 and thus, violating my Substantive Rights, and the Articles of Part 1 of ‘The Rights of Indigenous People’

26

27

28 PETITION FOR JUDICIAL REVIEWCHAPTER 15 RULE 1501NOTICE AND DEMAND TO DISMISSCORAM


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1 8. Petitioner furthers that No one shall be arbitrarily deprived of his nationality nor denied the right to change

2 his name.

4 9. Initial Issuing Authority: Judge MICHELLE HANGLEY is with the ‘want of jurisdiction’ by knowingly

5 and willingly conspiring (under a Color-of-Authority) to deny this Petitioner, Willie-Anthony: Brown,

6 (after this Petitioner made a reservation of rights and stating for the record; name, correct spelling of name,

7 and national status) her Inalienable Rights, the right to a Name and Nationality of her choosing, etc.

9 10. The State / Initial Issuing Authority: Judge MICHELLE HANGLEY/ Accuser(s) alleged and assumed the

10 Petitioner of being a Corporate Ward-ship 14th Amendment Artificial Negro Person / citizen, which

11 resulted in an unlawful arrest-of-rights, immunities, and liberties;

12

13 11. Petitioner contends all of which is in direct contradiction to, and a violation of, the Fourth (IV) Amendment

14 of the Constitution for the United States (Republic); violating Article VI of the Constitution, by way of

15 violating The Treaty of Peace and Friendship of EIGHTEEN HUNDRED-THRITY-SIX (1836) A.D.;

16 Congressional Resolution # 75, Philadelphia Pennsylvania; a violation of Article 15 of ‘The Universal

17 Declaration of Human Rights’ of Nineteen Hundred and Forty-Eight (1948) A.D. – General Assembly,

18 United Nations; a violation of ‘The Declaration of the Rights of The Child’

19

20 12. The State / Initial Issuing Authority: Judge MICHELLE HANGLEY/ Accuser(s)knowingly committed

21 ‘fraud’ against the Petitioner (<Willie-Anthony: Brown>) by abusing their authority, in that they failed to

22 correct a known violation; and did not aid in preventing said such abuse of authority, while having (by law)

23 the obligation to do so; and violated the Fifth Amendment of The Bill of Rights of Seventeen Hundred and

24 Ninety-One (1791) A.D.; impeding the Peoples’ right to due process under the Law, and equal protection of

25 the Law, Article 1 Section 10 of The Constitution for The United States of America (Republic) which

26 secures this Petitioner the right to contract and conspiracy to commit fraud against this Petitioner and

27 against the United States Republic.

28 PETITION FOR JUDICIAL REVIEWCHAPTER 15 RULE 1501NOTICE AND DEMAND TO DISMISSCORAM


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1

2 13. The proposition that the judgment of a court lacking jurisdiction is void traces back to the English Year

3 Books, see Bowser v. Collins, Y.B.Mich. 22 Edw. 4, f. 30, pl. 11, 145 Eng.Rep. 97 (1482), and was made

4 settled law by Lord Coke in Case of the Marshalsea, 10 Co.Rep. 68b, 77 Eng.Rep. 1027, 1041 (K.B. 1612).

5 Traditionally that proposition was embodied in the phrase coram non judice, "before a person not a judge" -

6 - meaning, in effect, that the proceeding in question was not a judicial proceeding because lawful judicial

7 authority was not present and could therefore not yield a judgment. American courts invalidated, or denied

8 recognition to, judgments that violated this common law principle long before the Fourteenth Amendment

9 was adopted. See, e.g., Grumon v. Raymond, 1 Conn. 40 (1814); Picquet v. Swan, 19 F. Cas. 609 (No. 11,

10 134) (CC Mass.1828); Dunn v. Dunn, 4 Paige 425 (N.Y.Ch. 1834); Evans v. Instine, 7 Ohio 273 (1835);

11 Steel v. Smith, 7 Watts & Serg. 447 (Pa.1844); Boswell's Lessee v. Otis, 50 U. S. 336, 51 U. S. 350 (1850).

12 In Pennoyer v. Neff, 95 U. S. 714, 95 U. S. 732 (1878), we announced that the judgment of a court lacking

13 personal jurisdiction violated the Due Process Clause of the Fourteenth Amendment as well.

14

15 14. Petitioner states that to determine whether the assertion of personal jurisdiction is consistent with due

16 process, Supreme Court precedence have long relied on the principles traditionally followed by American

17 courts in marking out the territorial limits of each State's authority. That criterion was first announced in

18 Pennoyer v. Neff, supra, in which we stated that due process "mean[s] a course of legal proceedings

19 according to those rules and principles which have been established in our systems of jurisprudence for the

20 protection and enforcement of private rights," id. at 733, including the "well-established principles of

21 public law respecting the jurisdiction of an independent State over persons and property," id. at 95 U. S.

22 722.

23

24 15. In what has become the classic expression of the criterion, we said in International Shoe Co. v.

25 Washington, 326 U. S. 310 (1945), that a state court's assertion of personal jurisdiction satisfies the Due

26 Process Clause if it does not violate "traditional notions of fair play and substantial justice.'" Id. at 326 U. S.

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28 PETITION FOR JUDICIAL REVIEWCHAPTER 15 RULE 1501NOTICE AND DEMAND TO DISMISSCORAM


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1 316, quoting Milliken v. Meyer, 311 U. S. 457, 311 U. S. 463 (1940). See also Insurance Corp. of Ireland v.

2 Compagnie des Bauxites de Guinee, 456 U. S. 694, 456 U. S. 703 (1982).

4 16. Among the most firmly established principles of personal jurisdiction in American tradition is that the

5 courts of a State have jurisdiction over nonresidents who are physically present in the State. The view

6 developed early that each State had the power to hale before its courts any individual who could be found

7 within its borders, and that, once having acquired jurisdiction over such a person by properly serving him

8 with process, the State could retain jurisdiction to enter judgment against him, no matter how fleeting his

9 visit.

10

11 17. Petitioner asserts that the law is so clear on this point that there are few decisions on it; Note,

12 Developments in the Law -- State Court Jurisdiction, 73 Harv.L.Rev. 909, 937-938 (1960). Opinions from

13 the courts of other States announced the rule in dictum. See, e.g., Reed v. Browning, 130 Ind. 575, 577, 30

14 N.E. 704, 705 (1892); Nathanson v. Spitz, 19 R.I. 70, 72, 31 A. 690, 691 (1895); McLeod v. Connecticut &

15 P.R. Co., 58 Vt. 727, 733-734, 6 A. 648, 649, 650 (1886); New Orleans J & G.N.R. Co. v. Wallace, 50

16 Miss. 244, 248-249 (1874); Wagner v. Hallack, 3 Colo. 176, 182-183 (1877); Downer v. Shaw, 22 N.H.

17 277, 281 (1851); Moore v. Smith, 41 Ky. 340, 341 (1842); Adair County Bank v. Forrey, 74 Neb. 811, 815,

18 105 N.W. 714, 715-716 (1905).

19

20 18. Petitioner offers that Most States, moreover, had statutes or common law rules that exempted from service

21 of process individuals who were brought into the forum by force or fraud, see, e.g., Wanzer v. Bright, 52

22 Ill. 35 (1869),

23

24 19. The view of most courts in the 19th century was that a court simply could not exercise in personam

25 jurisdiction over a nonresident who had not been personally served with process in the forum. See, e.g.,

26 Reber v. Wright, 68 Pa. 471, 476-477 (1871); Sturgis v. Fay, 16 Ind. 429, 431 (1861); Weil v. Lowenthal,

27

28 PETITION FOR JUDICIAL REVIEWCHAPTER 15 RULE 1501NOTICE AND DEMAND TO DISMISSCORAM


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1 10 Iowa 575, 578 (1860); Freeman, Law of Judgments, at 468-470; see also D'Arcy v. Ketchum, 52 U. S.

2 165, 53 U. S. 176 (1851); Knowles v. Gaslight & Coke Co., 86 U. S. 58 (1874).

4 20. Petitioner opines that, Pennoyer v. Neff, while renowned for its statement of the principle that the

5 Fourteenth Amendment prohibits such an exercise of jurisdiction, in fact set that forth only as dictum, and

6 decided the case (which involved a judgment rendered more than two years before the Fourteenth

7 Amendment's ratification) under "well established principles of public law." 95 U.S. at 95 U. S. 722.

9 21. Those principles, furthers Petitioner, embodied in the Due Process Clause, required that when proceedings

10 "Involv[e] merely a determination of the personal liability of the defendant, he must be brought within [the

11 court's] jurisdiction by service of process within the State, or his voluntary appearance."

12

13 22. Petitioner reasserts that the impetus for this action was the Initial Violation of the Fourth Amendment to be

14 free from unreasonable searches and seizures. This act has had the effect of forcing Petitioner into an

15 obligation to appear as “Forum Defendant” all of which is in violation of rights and immunities secured by

16 the Bill of Rights.

17

18 23. "Historically, the jurisdiction of courts to render judgment in personam is grounded on their de facto

19 power (being such in effect though not formally recognized) over the Petitioner's person. Hence his

20 presence within the territorial jurisdiction of a court was prerequisite to its rendition of a judgment

21 personally binding on him.

22

23 24. The fiction that an assertion of jurisdiction over property is anything but an assertion of jurisdiction over

24 the owner of the property supports an ancient form without substantial modern justification. Its continued

25 acceptance would serve only to allow state court jurisdiction that is fundamentally unfair to the Petitioner.

26 The problem with these assertions is that they justify the exercise of jurisdiction over everyone. The

27

28 PETITION FOR JUDICIAL REVIEWCHAPTER 15 RULE 1501NOTICE AND DEMAND TO DISMISSCORAM


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1 existence of a continuing tradition is not enough; fairness also must be considered; fairness does not exist

2 here because there is a continuing tradition.

4 25. In each case, personal service within the State was the exclusive basis for the judgment that jurisdiction

5 existed, and no other factor was relied upon. Petitioner, while he was forced into [the forum “State”]

6 acting in that capacity, has made a valid reservation of rights and does not waive his claims to such.

8 26. Petitioner avers generally that "[u]pon a summons, unless there is service within the jurisdiction, there can

9 be no judgment for want of appearance against the defendant." See Ibid. Gardner v. Thomas, 14 John. *134

10 (N.Y.1817), and Molony v. Dows, 8 Abb.Pr.R. 316 (N.Y. Common Pleas 1859)

11

12 27. Petitioner offers that It is held to be a principle of the common law that any nonresident defendant

13 voluntarily coming within the jurisdiction may be served with process and compelled to answer."

14 1 J. Wells, Jurisdiction of Courts 76 (1880).

15

16 28. I agree with Justice SCALIA that the Due Process Clause of the Fourteenth Amendment generally permits

17 a state court to exercise jurisdiction over a defendant if he is served with process while voluntarily present

18 in the forum State.

19

20 29. DICENTI IMPUNE NON PARETUR. “One who exercises jurisdiction out of his territory is not obeyed

21 with impunity. Dig. 2, 1, 20; Branch, Princ.; 10 Coke, 77; Story, Confl. Laws, § 539. “He who exercises

22 judicial authority beyond his proper limits cannot be obeyed with safety.”

23

24 30. Traditionally that proposition was embodied in the phrase coram non judice,"before a person not a judge" -

25 - meaning, in effect, that the proceeding in question was not a judicial proceeding because lawful judicial

26 authority was not present and could therefore not yield a judgment. American courts invalidated, or denied

27 recognition to, judgments that violated this common law principle long before the Fourteenth Amendment

28 PETITION FOR JUDICIAL REVIEWCHAPTER 15 RULE 1501NOTICE AND DEMAND TO DISMISSCORAM


NON JUDICELACK OF IN PERSONAM JURISDICTION - 9
1 was adopted. See, e.g., Grumon v. Raymond, 1 Conn. 40 (1814); Picquet v. Swan, 19 F. Cas. 609 (No. 11,

2 134) (CC Mass.1828); Dunn v. Dunn, 4 Paige 425 (N.Y.Ch. 1834); Evans v. Instine, 7 Ohio 273

3 (1835); Steel v. Smith, 7 Watts & Serg. 447 (Pa.1844); Boswell's Lessee v. Otis, 50 U. S. 336, 51 U. S.

4 350 (1850).

6 31. In Pennoyer v. Neff, 95 U. S. 714, 95 U. S. 732 (1878), Petitioner contends that the judgment of a court

7 lacking personal jurisdiction violates the Due Process Clause of the Fourteenth Amendment as well.

9 32. A Non-Judicial Person is without Jurisdiction to preside over any controversy more than $20 as guaranteed

10 by the Seventh Amendment. Therefore, this case must be dismissed.

11

12 Dated this day of Month, year.

13

14 Authorized Agent with Power of Attorney in Fact


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