Background
Katrina Allen used Blackbaud’s tuition payment platform to process monthly payments to the University School of Jackson. Beginning in November 2024, Allen sent letters to Blackbaud’s Chief Financial Officer proposing changes to her contract and claiming to “tender payment” via a “negotiable instrument.” Her communications referenced a durable power of attorney, all-capital name spellings, and references to herself as both a “principal” and an “agent,” along with concepts of accounts and fiduciary duties unrelated to the actual tuition contract.
Allen initially sued Blackbaud’s CFO by name in General Sessions Court in March 2025. That court dismissed the action in June 2025. Allen appealed to Circuit Court and filed additional pleadings reframing her claims as breach of contract and breach of fiduciary duty against Blackbaud (the corporate entity). Blackbaud moved to dismiss, attaching the actual terms and conditions of the tuition payment platform. The trial court granted the motion and awarded Blackbaud $10,000 in attorney’s fees.
The Court’s Holding
The Tennessee Court of Appeals affirmed the trial court’s dismissal, holding that Allen failed to state a claim for breach of contract or breach of fiduciary duty. The court determined that Allen’s arguments were grounded in discredited “sovereign citizen” and “redemptionist” legal theories—pseudo-legal doctrines rejected by courts nationwide. Under these theories, individuals claim a fictional distinction between their “real person” and a “strawman” identity created by government, and attempt to use UCC filings and alleged “negotiable instruments” to avoid financial obligations.
The court found that Allen’s breach of contract claim failed because she identified no actual provision in Blackbaud’s terms and conditions requiring the company to accept her recharacterized tuition invoice as payment. Her invocation of UCC provisions and references to “tender of payment” and “redemption” did not create enforceable contract rights. Since her breach of contract claim failed, her derivative breach of fiduciary duty claim also failed. The court further denied Allen’s motion to alter or amend the judgment, holding it merely sought to relitigate matters already decided.
Key Takeaways
- Sovereign citizen and redemptionist theories have no legal basis in Tennessee civil law and courts will dismiss complaints grounded in such theories on motions to dismiss
- Pro se litigants are held to the same pleading standards as represented parties and must identify specific contract provisions allegedly breached
- Terms and conditions attached to a motion to dismiss do not convert it to a summary judgment motion when those documents are required exhibits under the civil rules
- Motions to alter or amend cannot be used to relitigate settled issues or raise new legal theories not presented to the trial court
- Frivolous appeals can result in sanctions under Tennessee Code Annotated section 27-1-122
Why It Matters
This decision provides important Tennessee precedent rejecting sovereign citizen and redemptionist legal theories in civil practice. Courts across the country have struggled with voluminous filings based on these pseudo-legal doctrines, which the opinion notes are “dense, complex, and virtually unreadable.” By clearly articulating why these theories lack legal foundation—and providing detailed explanation of their origins in debt-avoidance schemes—the court establishes a framework for efficient dismissal.
For practitioners, the opinion reinforces that pro se litigants cannot circumvent contract law requirements through esoteric legal theories, and that trial courts properly consider required contract exhibits when evaluating motions to dismiss. The award of frivolous appeal damages signals Tennessee courts’ commitment to discouraging appeals based on rejected fringe theories.
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