Bray v. Manning
CourtOhio Court of Appeals
Date FiledSeptember 29, 2026
Docket26AP-225
StatusPublished
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Full Opinion
[Cite as Bray v. Manning, 2026-Ohio-3827.]
IN THE COURT OF APPEALS OF OHIO
TENTH APPELLATE DISTRICT
Mason Thompson Bray, :
Plaintiff-Appellant, : No. 26AP-225
(C.P.C. No. 25CV-10489)
v. :
(ACCELERATED CALENDAR)
Jason Manning et al., :
Defendants-Appellees. :
D E C I S I O N
Rendered on September 29, 2026
On brief: Mason Thompson Bray, pro se.
On brief: Shayla D. Favor, Prosecuting Attorney, Eli F.
Redfern, and Dexter D. Dorsey, for appellees Jason Manning,
the Honorable Stephen McIntosh, and Seth Enlow.
On brief: Samuel H. Shamansky, Co. L.P.A., Samuel H.
Shamansky, pro se, and Donald L. Regensburger, for
appellee Samuel H. Shamansky.
On brief: [D. Andrew Wilson], Attorney General, Thomas J.
Gillen, and Michael A. Walton, for State of Ohio appellees.
APPEAL from the Franklin County Court of Common Pleas
PER CURIAM.
{¶ 1} Plaintiff-appellant, Mason Thompson Bray, appeals from a judgment of the
Franklin County Court of Common Pleas granting defendants-appellees’ motions to
dismiss the action pursuant to Civ.R. 12(B)(6). For the following reasons, we affirm.
No. 26AP-225 2
I. Facts and Procedural History
{¶ 2} On December 8, 2025, appellant filed a document in the trial court titled
“Partial Complaint” in which he invoked “admiralty” and “maritime” jurisdiction against a
number of defendants, including public officials, and appeared to argue that the defendants
were operating contrary to “[e]quity, admiralty and maritime” jurisdiction. On
December 19 and 20, 2025, appellant filed additional documents with the title, “Master
Bill of Lading” which purported to raise “congressional questions” and called into question
the validity and construction of the United States Constitution.
{¶ 3} Appellees moved to dismiss the pleadings pursuant to Civ.R. 12(B)(6).
{¶ 4} On February 17, 2026, the trial court granted the motions to dismiss. The
entry noted that the dismissal applied to all of the claims in appellant’s complaint and
amended complaint and it dismissed as moot any other pending motions.
II. Assignments of Error
{¶ 5} Appellant timely appeals. Rather than assignments of error, appellant
presents the following five issues for review:
1. Whether the Court of Common Pleas erred by dismissing
the case for lack of Subject Matter Jurisdiction and failure
to state a claim upon which relief may be granted instead
of addressing the substantive admiralty and
maritime treaty-based merits of the complaint.
2. Whether the court’s failure to rule on the controlling
questions of validity and construction under Article VI of
the Constitution of the United States and the 1786
Treaty of Marrackech constitutes reversible error.
3. Whether, under Section 32 of the Judiciary Act of 1789, the
trial court was obligated to render judgment “according as
the right of the cause and matter in law shall appear,”
without regard to form.
4. Whether the Supreme Court of Ohio or Ohio Court of
Appeals, as the appellate tribunal, must apply treaty
obligations as self-executing and binding on all state
judges.
5. Whether the Validity and Construction of the Constitution
of the United States/U.S. Constitution and laws of the
United States including Ohio Revised Code (United States
No. 26AP-225 3
of America in Congress Assembled) is Repugnant to the
Articles of Confederation (United States in Congress
assembled) and whether the Construction of the
Constitution of the United States is Repugnant to the 1786
Treaty of Marrakech.
III. Discussion
{¶ 6} We review a trial court’s decision granting a motion to dismiss under Civ.R.
12(B)(6) for failure to state a claim upon which relief may be granted under a de novo
standard of review. Perrysburg Twp. v. Rossford, 2004-Ohio-4362, ¶ 5. Under this
standard of review, we independently review the record and afford no deference to the trial
court’s decision. Brust v. Franklin Cty. Sheriff’s Office, 2015-Ohio-5090, ¶ 5 (10th Dist.),
citing State v. Romage, 2012-Ohio-3381, ¶ 6 (10th Dist.). “A complaint should not be
dismissed unless it appears ‘beyond doubt from the complaint that the plaintiff can prove
no set of facts entitling him to recovery.’ ” Lunsford v. Sterilite of Ohio, L.L.C., 2020-Ohio-
4193, ¶ 22, quoting O’Brien v. Univ. Community Tenants Union, Inc., 42 Ohio St.2d 242,
syllabus (1975).
{¶ 7} Appellant’s brief appears to repeat many of the concepts from his complaint
and amended complaint rather than focus specifically on why the trial court’s decision to
dismiss his claims on the basis of Civ.R. 12(B)(6) should be reversed. For example, in the
conclusion of his appellate brief, in addition to asking this court to reverse the trial court’s
decision, appellant asks this court to remand the matter “with instructions to proceed under
admiralty and maritime jurisdiction,” affirm that the court of common pleas “is a court of
chancery/equity,” and “[o]rder restoration of Appellant’s rights as Moor and not Subject to
the laws of the United States to be set at liberty from detainments, restore property, and
protections secured under the 1786 Treaty of Marrakesh and applicable admiralty law and
correct the abstract to reflect that i am in Control of my Berth my estate through my master
bill of lading with my proper flag of my allegiance to the Shereefian Empire.” (Sic passim.)
(Appellant’s Brief at 19.) This is relief beyond the scope of our appellate review.
{¶ 8} Appellant also notes in his brief that he denies being a United States citizen
or that he is subject to the jurisdiction of the United States.
{¶ 9} To the extent the arguments appellant has asserted in his complaint and
amended complaint, as well as to this court on appeal, rely on the types of assertions that
No. 26AP-225 4
have been described as “sovereign citizen” theories, we find them to lack any legal merit.
See First Bank of Ohio v. Vidal, 2025-Ohio-2876, ¶ 6 (10th Dist.); Columbus v. ACM Vision,
V, L.L.C., 2021-Ohio-925, ¶ 20 (10th Dist.); see also United States v. Leugers, 2016 U.S.
Dist. LEXIS 183060 (S.D.Ohio Sept. 1, 2016). Indeed, Federal and Ohio courts have
rejected such arguments as “patently frivolous.” Id. See U.S. Bank Natl. Assn. v. Martin,
2018 Ohio App. LEXIS 4387 (1st Dist. Oct. 5, 2018), discretionary appeal not allowed,
2019-Ohio-173 (“[a]ny claim that the court lacked jurisdiction over [appellant] based on a
‘sovereign-citizen’ argument is wholly frivolous”); State v. Few, 2015-Ohio-2292, ¶ 6 (2d
Dist.) (rejecting sovereign citizen argument challenging jurisdiction of court, which
included references to both civil common law and admiralty law, as “wholly frivolous”).
{¶ 10} Moreover, on the merits of the trial court’s decision to dismiss appellant’s
claims, we do not find error. The court explained that it agreed with appellees “that they
are not able to discern from the pleadings the nature of the action nor claims asserted
against any particular Defendant.” (Feb. 17, 2026 Jgmt. Entry at 5.) The court concluded
that “the complaint and amended complaint do not give Defendants fair notice of the nature
of the claims against them nor the relief requested by Plaintiff.” (Feb. 17, 2026 Jgmt. Entry
at 5.)
{¶ 11} On the facts of this case, we agree with the trial court’s assessment of the
pleadings. We find that the pleadings fail to allege any cognizable cause of action.
Therefore, appellant’s appeal is without merit.
IV. Conclusion
{¶ 12} Based on the foregoing, we affirm the judgment of the Franklin County Court
of Common Pleas.
Judgment affirmed.
DORRIAN, JAMISON, and DINGUS, JJ., concur.