Note: The following text contains strong opinions, personal attacks, and potentially controversial claims (e.g., regarding specific judges, Freemasonry, political motives). The following text has been toned down to remove some of the most inflammatory language for professionalism; however, the underlying assertions remain as part of the appellant’s argument.

Disclaimer: The provided text does not constitute legal advice, nor does it verify the accuracy of the factual claims or legal arguments made by the appellant. Consult with a qualified legal professional for advice specific to any legal matter.

Appellant’s Brief

PART ONE: History and Facts

Appellant, Matthew P. Dec, proceeding pro se, submits this brief under the Court’s jurisdiction pursuant to 42 U.S.C. § 1983, the Trafficking Victims Protection Act (TVPA), the Racketeer Influenced and Corrupt Organizations Act (RICO), and various federal tax issues. This brief details the underlying and currently unaddressed causes of action, presenting facts intended to illuminate the implications thereof.

1. This case originates from events on June 6, 2023, during which Appellant engaged in a telephonic communication with Magistrate O’Donnell’s office regarding jurisdictional disputes. Any matters related to previous suits (e.g., 23-cv-0072) are presented solely for historical context and are not the basis of the current Cause of Action.
2. By way of analogy: Mr. Smith travels three hours from Butler, PA, to Greensburg, PA, performs a roof repair for $400, receives a check, drives three hours back to Butler, and deposits it. The next day, the check bounces. Mr. Smith contacts his local magistrate and is informed he must travel back to Greensburg to file a claim with the magistrate in that district.
3. Appellant contends that either the secretary and Constable Geagan misstated the content of the communication or provided false testimony under oath. Appellant asserts the latter.
4. Appellant expressed surprise upon learning of the charges, reportedly stating words to the effect of, “Wait until they play the recording and discover that the PCP USA is a website, not a street gang.”
5. Appellant was incarcerated for 50 days at the Butler County Prison on $250,000 bail without receiving a preliminary hearing. Appellant alleges this violated Due Process rights, citing Pennsylvania Rule of Criminal Procedure 540(G)(1) which requires a preliminary hearing within 14 days of arrest, affording the Defendant the right to confront accusers. Appellant further alleges that during this period, courts and media disseminated false accusations against him.
6. Appellant asserts that no recording or other tangible evidence exists to substantiate the commission of a crime. The prosecution appears reliant on conflicting testimonial accounts (“they said, he said”) regarding alleged assaults and terroristic threats. Furthermore, no stenographer was present during the preliminary hearing.
7. Appellant alleges deceptive practices by lower court officials involving former magistrate Wayne Seibel (now a civilian) from Evans City, Butler County. Appellant claims Mr. Seibel is a personal friend of Constable Geagan (a witness against Appellant) and that Mr. Seibel previously employed Constable Geagan’s services during his tenure as magistrate. This same Evans City magistrate’s office initially set Appellant’s bail at $250,000.
8. Appellant argues that due to extensive media coverage generating alleged falsehoods and the association of all local judges with Constable Geagan and Magistrate O’Donnell’s office, the rules of recusal required an out-of-county judge to preside.
9. Appellant alleges that Mr. Seibel, acting as a civilian, committed Fraud upon the Court by intentionally impersonating a sitting out-of-county judge, thereby forfeiting any potential judicial immunity he might have otherwise possessed.
10. Appellant argues that even if evidence points towards a conspiracy, judicial immunity, as interpreted prior to the Bruen decision, grants judges broad protection, potentially enabling the misuse of courts against political or moral adversaries. Appellant characterises this dynamic as a conflict (e.g., “Freemasons v. The People”).
11. Appellant contends that accountability is further limited by the actions of State Representatives, alleging they commit constitutional errors and benefit from 11th Amendment immunity similar to that of the judiciary, creating an unresolved cycle of grievances.
12. Appellant asserts that the current situation contravenes the principles intended by the Nation’s Founders, who, Appellant believes, would have rejected such developments.
13. Appellant acknowledges the constitutional analysis framework established in New York State Rifle & Pistol Assn., Inc. v. Bruen, conceding it provides a sound basis for evaluating constitutional issues based on historical text and tradition.
14. Appellant alleges widespread corruption involving local elected officials (commissioners, judges, magistrates, District Attorney) that constitutes violations under 42 U.S.C. § 1983, TVPA, RICO, and federal tax regulations (IRS tax fraud). Understanding the history and conduct of these officials is necessary to demonstrate the alleged pattern of racketeering and abuse of process.
15. Therefore, it is necessary for Appellant to expound upon the historical context relevant to this case.
16. Prior to the charges initiated on June 6, 2023, Appellant had created and was preparing to launch a political initiative designed to increase accountability for police, court officials, legislators, and corrections personnel.
17. This initiative involved the creation of a third political party founded by Appellant, officially named the “People’s Constitutional Party” (PCP), along with a new Christian 501(c)(3) denomination titled the “Assemblies of a Standard Raised” (ASR).
18. The PCP structure subdivided the United States into its 3147 counties (or parishes), aiming to empower individuals or groups to challenge established political figures within their regions, utilizing integrated social media platforms on each county-specific website.
19. Appellant claims this model negates traditional campaign costs by leveraging social media, offering a free platform with potential reach to anyone with internet access.
20. This third-party option includes plans to field 13 candidates in the presidential election cycle, providing a cost-free platform and media projection capabilities (see: https://thepcpusa.com/13-candidates/). It also proposes the political unionization of convicted felons (see: https://thepcpusa.com/felons-union/) and opportunities for individuals to become “CEOs” of county-level 501(c)(4), 501(c)(3), and other entities under various IRS codes (see: https://thepcpusa.com/county-sites/), aligning with the Bruen decision’s focus on historical principles.
21. The “ASR/PCP of Butler, Pennsylvania” was intended as a flagship site to demonstrate how this model could combat local corruption.
22. Two cases were featured on this site: Cheyenne L. Goodin v. Butler County, et al., and Appellant’s own pending challenge in the Third Circuit (No. 23-2765) appealing the dismissal (W.D. Pa. No. 2:22-cv-1290) of a suit alleging state punishment for exercising a constitutional right. The dismissal was based on 11th Amendment immunity grounds.
23. Regarding Cheyenne Goodin v. Butler, et al. (W.D. Pa. No. 2:21-cv-00265), Appellant alleges the District Court dismissed the case as “Frivolous and Malicious.” Appellant claims the case involved a mother whose child was fraudulently obtained by a man who allegedly falsified documents and committed perjury claiming paternity. Appellant asserts this man was known to be dangerous and that the child suffered sexual abuse as a result of the court’s actions granting him custody. Appellant makes critical remarks regarding Chief Judge Mark Hornak who dismissed the case.
24. Appellant alleges the man granted custody by Butler County judges and Judge Hornak, despite Ms. Goodin’s warnings, was later arrested for multiple DUIs, drug dealing (fentanyl/heroin, crystal meth), and is reportedly under investigation for overdose deaths. Appellant claims the toddler was reported to have been sexually molested by the subsequent foster family and the man is now jailed on $100,000 bail.
25. Appellant provides further distressing details about Ms. Goodin’s subsequent situation, alleging her relapse into addiction, endangerment, and exploitation, attributing this tragic outcome to the court system’s alleged failures and potential cover-up motives.
26. Appellant alleges that the damage inflicted upon Ms. Goodin and her child resulted from judicial misconduct, claiming Attorney Mike Zunder advised his client to lie, Judge Michael Yeager knowingly allowed the alleged perjury, and the court improperly granted custody due to financial influence.
27. Appellant asserts that filings prepared for Ms. Goodin would lead a jury to find negligence and/or corruption on the part of Judge Yeager, Attorney Zunder and Associates, DM Kevin O’Donnell, DA Goldinger, and CYS (Children and Youth Services).
28. Appellant notes a long history of conflict with the Butler County system but states the current situation represents an escalation.
29. Appellant recounts another incident involving a senior judge (reportedly from Armstrong County) presiding over one of Ms. Goodin’s cases against Attorney Zunder. Appellant alleges this judge refused to allow a witness (Appellant) to speak, mocked Ms. Goodin, and concurred with granting custody to the disputed father despite severe allegations against him. Appellant includes commentary on Freemasonry, linking it to alleged cult-like behavior and corruption within the legal system.
30. Appellant states this judge previously silenced him in court, threatening removal by deputies. Appellant witnessed what he perceived as a coordinated effort to dismiss Ms. Goodin’s legitimate concerns. (Appellant requests confidentiality regarding details of the Cheyenne Goodin case due to the involvement of a minor and allegations of sexual assault, but asserts these allegations waive 11th Amendment protections under PA law and demand investigation by the Attorney General.)
31. Appellant contends these background issues, particularly his intention to use the Butler ASR/PCP platform to expose alleged corruption and challenge incumbent officials (DA, commissioners, magistrates), provided the motive for alleged vindictive/malicious prosecution and weaponization of the courts, resulting in his imprisonment and allowing officials to retain their positions.
32. While these events provide context and support claims of malicious prosecution, they are not the sole basis of the current action.
33. The primary cause of this suit stems from Appellant being placed on House Arrest as a condition of bail, requiring him to pay $450 per month to a 501(c)(3) religious charity organization (Glade Run Lutheran Services), under threat of bail revocation and re-incarceration. Appellant seeks an injunction prohibiting the continuation of this practice.
34. Appellant asserts it is illegal for a county house arrest program to operate through a 501(c)(3) charity, arguing this constitutes violations of both the TVPA and RICO, citing the Third Circuit’s precedential ruling in No. 21-2846.
35. Referencing the Third Circuit’s ruling in No. 21-2846, Appellant highlights the established violation of the 13th Amendment:

    “Section 1 of the Thirteenth Amendment to the Constitution of the United States states: ‘Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, or any place subject to their jurisdiction.’1 …In Kozminski, the Supreme Court held that the phrase ‘involuntary servitude,’ as used in 18 U.S.C. § 1584 and the Thirteenth Amendment, is ‘limited to cases involving the compulsion of services by the use or threatened use of physical or legal coercion.’2 487 U.S. at 948. … …’Modern day examples of involuntary servitude [under the Thirteenth Amendment] have been limited to labor camps, isolated religious sects, or forced confinement.’ Steirer v. Bethlehem Area Sch. Dist., 987 F.2d 989, 999 (3d Cir. 1993).” (Quoting Third Circuit No. 21-2846)

36. Appellant distinguishes his 13th Amendment claim by noting he is presumed innocent while on $25,000 bail. Forcing him to pay a 501(c)(3) religious organization $450 monthly for home confinement under threat of bail revocation, he argues, constitutes involuntary servitude distinct from cases involving convicted individuals or compelled labor scenarios.
37. Regarding the TVPA charge, Appellant cites the Third Circuit’s analysis in No. 21-2846:

    “…Congress heeded the Court’s call in Kozminski… when it passed the TVPA, which defines forced labor broader than Kozminski’s definition of involuntary servitude… by criminalizing knowingly provid[ing] or obtain[ing] the labor or services of a person by any one of, or by any combination of, the following means— (1) by means of force, threats of force, physical restraint, or threats of physical restraint…; (2) by means of serious harm or threats of serious harm…; (3) By means of the abuse or threatened abuse of law or legal process; or (4) by means of any scheme, plan, or pattern intended to cause the person to believe that, if that person did not perform such labor or services, that person or another person would suffer serious harm or physical restraint[.] 18 U.S.C § 1589(a). … Congress also broadly defined ‘abuse or threatened abuse of law or legal process’ as the use or threatened use of a law or legal process… in any manner or for any purpose for which the law was not designed, in order to exert pressure on another person… 18 U.S.C. § 1589(c)(1). …the TVPA clearly encompasses a broad range of conduct… [including] circumstances in which the person whose labor is being exploited is faced with any number of choices as an alternative to working… And the TVPA bars getting or giving labor ‘by any one of, or by any combination of, the [prohibited] means,’ indicating that a victim can face more than a binary choice and remain protected… The TVPA’s more-expansive definitions of coercion reflect the ‘increasingly subtle’ ways by which labor may be forced… including both physical and ‘nonphysical forms of coercion,’… Defendants’ conditioning of plaintiffs’ access to the work release program… on a period of nearly free, grueling labor…, is an abuse of law or legal process under the TVPA. That is so because it is a use of the work release program in a manner for which it was not designed, in order to pressure3 plaintiffs to work…” (Quoting Third Circuit No. 21-2846)

38. Appellant argues by analogy: If compelling individuals owing child support to perform low-wage labor constitutes using work release for an unintended purpose (abuse of process under TVPA), then imposing house arrest requiring $450 monthly payments to a 501(c)(3) religious charity upon individuals presumed innocent constitutes a more significant abuse of process. Appellant questions whether officials were unaware of the alleged illegality.
39. As a result of these alleged actions, Appellant contends the defendants, acting in their official and/or individual capacities, have violated the TVPA, RICO, the 1st, 4th, 5th, 8th, 13th, and 14th Amendments, and committed abuse of process, unjust enrichment, white-collar tax crimes, and conspiracy to violate civil rights (See attached Motion for Added Defendants).
40. Appellant avers that these defendants conspired, allegedly motivated by a “common cult cause” (referencing earlier mentions of Freemasonry), to commit and continue committing the acts described herein.
41. Appellant concludes this section of the Brief upon this foundation, awaits the Defendants’ response, and intends to further perfect the case in reply thereto.
42. Appellant demands a Jury Trial.
43. Appellant alleges that Glade Run Lutheran Services currently functions as a “government instrumentality” by enforcing court-ordered house arrest, allegedly extorting $450 monthly from citizens on bail as a condition thereof, receiving county funding for these services, and declaring approximately $22 million in 2022 county funding as tax-free charitable donations.
44. Appellant cites IRS Revenue Ruling 60-384 and related case law:

    “As noted above, Rev. Rul. 60-384 establishes that a state or Municipality function cannot qualify as an IRC 501c(3) organization since its purposes are not exclusively purposes described in IRC 501(c)(3). Furthermore, an organization wholly-owned by a state or a municipality is not a clear counterpart of an IRC 501(c)(3) organization and is not entitled to exemption if it exercises powers that are governmental in nature, that is, ‘enforcement or regulatory powers in the public interest such as health, welfare or safety.’ Exemption is denied because the organization ‘has purposes or powers which are beyond those described in section 501(c)(3).’ (This position has been implicitly supported by the courts. See Estate of Leslie Johnson v. Commissioner 56 T.C. 944 (1971), acq. 1973-2 C.B. 2; Old Colony Trust Company v. United States, 438 F. 2d 684 (1st Cir. 1970).)”

45. Appellant argues that compelling defendants who are presumed innocent and have posted bail into a punitive house arrest program requiring $450 monthly payments to a 501(c)(3) church entity, under threat of incarceration, constitutes a violation of the TVPA (using a system of punishment intended for convicted individuals to extort money from those on bail) via abuse of process. This argument is supported by “common sense” points: A. An ankle monitor is ineffective against a defendant determined to commit violence, as they could simply remove it. B. An ankle monitor provides a convenient alibi for a defendant orchestrating crime remotely while confined. C. An ankle monitor does not prevent a defendant from absconding, as they can remove it and flee. D. Therefore, Appellant argues, there is no justifiable public safety reason for imposing this punitive measure and financial extortion via a 501(c)(3) on bailed individuals, suggesting the true purpose is racketeering and oppression akin to authoritarian regimes silencing political dissent. (Citing Wikipedia’s description of house arrest used against political dissidents, often involving monitored or restricted communication).
46. Appellant claims the conditions of his house arrest exemplify abuse of process aimed at silencing dissent: (a) Permitted to work for others but forbidden to bid on his own jobs. (b) After five months, permitted to attend a church but forbidden to continue building his own church/political organization (referencing www.thepcpusa.com).
47. Appellant believes this Brief overcomes any suggestion that the claims are “frivolous” (referencing an alleged refusal by DM Eddy Reed to accept the filing) and respectfully petitions this Court to review his claims.

PART TWO: Applicable Civil, State, and Federal Law

INTRODUCTION

48. The United States Constitution is the Supreme Law of the Land, governing all jurisdictions and officials acting under color of law.
49. Appellant reiterates that all officials are subject to the Constitution, questioning the extent of immunities that might permit actions contrary to its principles, which the Framers would have found repugnant.
50. The Supreme Court’s decision in New York State Rifle & Pistol Association v. Bruen mandates that constitutional issues be resolved based on the text, history, and tradition of the Constitution, reflecting the Framers’ original intent.
51. Appellant expresses concern over judicial interpretations allegedly deviating from this standard, potentially influenced by contemporary ideologies (“woke”), and shielded by immunity. Appellant contends this leads to the “weaponization” of courts, resulting in unchecked maliciousness, vindictive prosecution, and local conspiracies involving judges, DAs, police, defense attorneys, and elected officials, potentially linked by affiliations such as Masonry, acting for self-serving agendas.
52. Appellant repeats that this contradicts the vision of the Nation’s Forefathers.
53. Appellant reaffirms the Bruen standard requiring courts to adhere to the historical understanding of the Constitution when deciding constitutional issues.
54. The specific issues in this case involve the 1st, 4th, 5th, 8th, 13th, and 14th Amendments to the Constitution, as well as the TVPA, RICO, and federal tax laws. These rights primarily stem from the Bill of Rights and the 14th Amendment.
55. The Preamble to the Bill of Rights itself underscores its purpose:

    “Congress of the United States begun and held at the City of New-York, on Wednesday of March 4, 1789; THE Conventions of a number of the States, having at the time of their adopting the Constitution, expressed a Desire, in order to Prevent misconstruction4 or abuse of its Powers, that further Declaratory and Restrictive Clauses should be added: And as extending the ground of Public confidence in the Government, will best Ensure the Beneficent ends of its Institution…”5

56. To understand the significance of these “Declaratory and Restrictive Clauses,” historical context is necessary.
57. On June 7, 1776, Richard Henry Lee proposed the Lee Resolution to the Second Continental Congress, suggesting: A) Independence from Great Britain, B) Foreign alliances, and C) A confederation of the States.
58. The Articles of Confederation were agreed upon by Congress on November 15, 1777, and fully ratified by March 1, 1781, serving as the governing document for eight years.
59. However, the Articles contained significant flaws, largely stemming from the public’s reluctance to grant substantial power to a central government after fighting against British rule.
60. Congress under the Articles was intentionally weak: A. No power to tax; reliant on requests to states (often ignored). B. Each state had one vote, regardless of size or contribution. C. Limited military authority; reliant on state troop requests (often unfulfilled). D. No authority to compel delegate attendance, slowing proceedings significantly. E. Could make decisions but lacked enforcement power. F. Could not regulate interstate trade, leading to competing state laws and tariffs. G. States retained significant sovereignty apart from limited federal powers (war, diplomacy, weights/measures, interstate arbitration). H. Required unanimous consent for decisions, allowing a single state to veto measures.
61. These deficiencies led to the Constitutional Convention, beginning with the “Virginia Plan” presented on May 29, 1787, which aimed to:

    “…Resolved that the Articles of Confederation ought to be so corrected ; enlarged as to accomplish the objects proposed by their institution; namely, ‘common defense, security of Liberty, and general welfare….'”

62. The subsequent debate involved Federalists (some wary of enumerating rights, fearing it implied unenumerated rights were unprotected) and Anti-Federalists (demanding a Bill of Rights to guarantee specific liberties against government infringement). The Anti-Federalist view prevailed, resulting in the Bill of Rights being established as “Declaratory and Restrictive Clauses” intended to be inviolate protections for all citizens, immune from legislative or judicial tampering. Appellant argues these rights were understood to be fully retained even after punishment, and designed explicitly to prevent government overreach like disarming the populace or restricting speech and religion.