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Constitutional Sheriffs and Peace Officers Association
Constitutional Sheriffs and Peace Officers Association
Constitutional Sheriffs and Peace Officers Association
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The Constitutional Sheriffs and Peace Officers Association (CSPOA) is a political organization of local police officials in the United States who contend that federal and state government authorities are subordinate to the local authority of county sheriffs and police. Self-described constitutional sheriffs assert that they are the supreme legal authority with the power and duty to defy or disregard laws they regard as unconstitutional.[2][3] As a result, they may sometimes be referred to as sovereign sheriffs.[4] The movement is related to previous nullification and interposition notions,[1] and promotes such efforts.[5] It has been described as far-right by the Southern Poverty Law Center.[6]

Key Information

History

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The association was founded in 2011 by former Arizona sheriff Richard Mack who was a board member of the Oath Keepers at the time.[7]

By 2023, the association was being led by Sam Bushman, who has been scrutinized for his affiliation with neo-Confederates and white nationalists, including a close friendship with radio host James Edwards.[8]

Membership Numbers

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The CSPOA has claimed various membership numbers. In 2017, the association said it had 4,500 dues-paying members, with more than 200 sheriffs among them.[1] In 2020, the group claimed a membership of 400.[3] In 2021, Mack said that 300 of the 3,000 sheriffs in the U.S. were members of the association.[7] However, no reliable numbers are available as, according to the Associated Press, details of the group's operations, including membership numbers, are closely held.[9]

Ideology

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The movement has some ideological similarities with the self-styled patriot movement and sovereign citizen movement, and some members of those movements also espouse "constitutional sheriff" ideology.[10][1] The "constitutional sheriff" or "county supremacy" movement itself arose from the far-right Posse Comitatus, a racist and anti-Semitic group of the 1970s and 1980s that also defined the county sheriff as the highest "legitimate" authority in the country,[1][6] and was characterized by paramilitary figures and the promotion of conspiracy theories.[1] Sheriffs are not mentioned in the U.S. Constitution.[11] The ideological basis of the sheriffs' movement is instead based on various incorrect historical and legal claims, relying on a pretense that the historic powers of the high sheriff of an English shire apply in the U.S. regardless of subsequent legal developments.[1]

A number of county sheriffs in the United States have expressed sympathy with the movement's goals and have publicly vowed not to enforce laws they deem unconstitutional.[2] Law professor Robert L. Tsai writes that, "in practice constitutional sheriffs and their followers tend to occupy the edges of anti-government conservatism, organizing themselves to promote gun rights and property rights, to resist tax laws, national healthcare, gay marriage."[1] Members of the movement have vowed not to enforce gun laws,[12] public health measures adopted to combat the 2020 COVID-19 pandemic,[2][3][13] and federal land use regulations.[3] Sheriffs who refuse to enforce land-use laws facilitate the illegal use of public land (for example, for livestock grazing or all-terrain vehicles use) and in some cases have threatened Bureau of Land Management (BLM) employees.[3] A research study of reports from 1995 to 2015 found that counties with sheriffs who are members of the movement "have higher rates of violence against BLM employees than other Western counties."[3]

The movement has attracted support from some landowners, county commissioners, law enforcement figures (in particular Richard Mack and Joe Arpaio), and some politicians who have played on "fears of federal officials intruding on property rights and gun rights."[1]

Involvement in presidential elections

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In the aftermath of the 2020 election, Barry County, Michigan, Sheriff Dar Leaf, a member of the constitutional sheriffs movement, tried to seize voting machines in an effort to prove election fraud. He also took legal action in December 2020, attempting to stop local clerks from deleting election records. The chief judge of the federal court in Grand Rapids denied the request.[14]

In the run-up to the 2024 election the group has been training armed militias, building ties to Trump supporters and building "posses" to patrol polling stations.[15]

References

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Constitutional Sheriffs and Peace Officers Association

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The Constitutional Sheriffs and Peace Officers Association (CSPOA) is a dedicated to educating sheriffs, peace officers, and citizens on the constitutional authority of county sheriffs as the ultimate law enforcement officials within their jurisdictions, empowered to uphold the U.S. Constitution against overreaching federal or state mandates. Founded in 2011 by , a former sheriff of , who successfully challenged federal overreach in the landmark Supreme Court case Printz v. United States, the CSPOA emphasizes that elected sheriffs hold a duty to protect citizens' rights by interposing their authority when higher governments enact unconstitutional laws or policies. The association's core mission involves training programs, seminars, and resources to reinforce peace officers' oaths of office, promoting principles such as and individual liberties while rejecting excessive force or authoritarian enforcement tactics. It operates through initiatives like the CSPOA Posse, a membership network providing updates, strategic guidance, and community engagement to foster peaceful restoration of constitutional governance. While CSPOA claims to represent thousands of members and has influenced sheriff elections across multiple states by endorsing candidates committed to these tenets, its advocacy for sheriffs' supremacy over federal directives has drawn scrutiny from federal law enforcement and civil rights organizations, which characterize it as promoting resistance to lawful authority—though the group maintains its stance aligns strictly with founding legal precedents and empirical limits on centralized power.

Founding and History

Establishment by Richard Mack in 2011

Richard Mack, the former sheriff of Graham County, Arizona, from 1988 to 1996, established the Constitutional Sheriffs and Peace Officers Association (CSPOA) in 2011. Mack had previously gained national prominence for challenging federal mandates as sheriff, particularly by joining Jay Printz in suing the U.S. government over the Brady Handgun Violence Prevention Act's requirement for local officials to conduct background checks on firearm purchases; the U.S. Supreme Court ruled in their favor in Printz v. United States (1997), affirming that the federal government could not commandeer state or local officers to enforce federal regulatory programs. This experience underscored Mack's view of sheriffs as constitutional guardians empowered to resist federal overreach, motivating the creation of CSPOA as a dedicated organization to promote this doctrine among law enforcement. The association was formed to educate sheriffs, peace officers, and citizens on the and the sheriff's role as the highest elected within boundaries, capable of interposing against unconstitutional laws or federal actions. Mack positioned CSPOA as a response to perceived erosions of local , drawing from historical precedents like 18th-century sheriff traditions and emphasizing that sheriffs derive directly from the people rather than federal or state hierarchies. Initial efforts focused on recruitment through seminars, training, and advocacy materials, aiming to build a network of "constitutional sheriffs" committed to upholding the over conflicting directives. At its inception, CSPOA's mission explicitly rejected federal supremacy in local matters, asserting that sheriffs hold veto power over enforcement of laws they deem violative of constitutional principles—a stance rooted in Mack's interpretation of the 10th Amendment and anti-commandeering precedents. While early membership details are sparse, the organization quickly aligned with broader Second Amendment and limited-government movements, reflecting Mack's prior involvement in groups like the , though CSPOA emphasized sheriff-specific duties. This foundational framework has since defined CSPOA's operations, prioritizing oath-based resistance to perceived tyranny without endorsing violence or unlawful conduct.

Expansion and Key Milestones (2012–2020)

Following the establishment of the Constitutional Sheriffs and Peace Officers Association (CSPOA) in 2011, the organization held its inaugural national convention in , , on January 30, 2012, under the banner "No Sheriff Left Behind." This event marked a pivotal expansion effort, drawing sheriffs and peace officers to discuss constitutional principles and resistance to perceived federal overreach, with founder emphasizing the sheriff's supreme within jurisdictions. Throughout the mid-2010s, CSPOA grew through Mack's extensive outreach, including speaking engagements at approximately 70 sheriffs' offices and gatherings, where he promoted the group's doctrine of sheriff-led nullification of unconstitutional laws. By 2016, membership had expanded to around 5,000, encompassing sheriffs, deputies, and allied peace officers across multiple states, supported by training seminars focused on oath-keeping and interposing against federal mandates. A significant milestone occurred in 2014 during the in , where Mack personally participated alongside militia supporters in defying federal enforcement of grazing fees, framing it as a defense of constitutional ranching rights; this event elevated CSPOA's profile and attracted further adherents skeptical of federal land authority. The association continued annual conventions and expanded educational programs, certifying "constitutional sheriffs" who pledged to prioritize county-level constitutional fidelity over state or federal directives, fostering a network resistant to policies on firearms, , and .

Recent Developments (2021–Present)

In 2021, CSPOA intensified its outreach amid opposition to mandates and federal election oversight, with founder conducting 72 rallies, training seminars, or events across 27 states, accumulating approximately 100,000 miles in travel. The organization described this period as historic, emphasizing sheriff-led resistance to perceived federal overreach, including business closures and orders. Mack's activities aligned with broader efforts to recruit sheriffs, claiming around 300 U.S. sheriffs as members by that year, though independent verification of exact figures remains limited. By November 2022, Mack transitioned from formal but retained an advisory leadership role, as announced by CSPOA. During a that month, he reported training nearly 1,000 and thousands of peace officers nationwide on doctrines of local authority over federal directives. A 2023 survey of over 3,000 U.S. yielded 500 responses, with few formal CSPOA memberships but widespread agreement on core principles like sheriff supremacy in enforcing constitutional limits on federal power. This reflected expanding ideological influence, evidenced by trainings in multiple states and endorsements from elected officials, including county judges attending CSPOA sessions. From 2023 onward, CSPOA sustained operations through online courses and weekly webinars, focusing on oath-of-office and nullification strategies. Membership claims grew harder to quantify, but the group's reach expanded via state chapters and events promoting intervention in issues like . In July 2025, Mack headlined a constitutional rally in , advocating posse-style and -led liberty restoration. CSPOA issued endorsements for enhanced policies, positioning sheriffs as frontline defenders against federal inaction. These efforts underscore persistent advocacy for decentralized authority, with empirical traction in sheriff surveys despite limited formal affiliations.

The Supremacy of County Sheriffs

The Constitutional Sheriffs and Peace Officers Association (CSPOA) maintains that the county sheriff possesses ultimate authority within their , superseding that of any federal, state, or local agent operating therein. According to CSPOA doctrine, this supremacy stems from the sheriff's status as an elected constitutional officer directly accountable to the people, empowered to enforce the U.S. Constitution and state constitutions as the supreme . The organization emphasizes that sheriffs swear an oath to defend these constitutions against all enemies, foreign and domestic, positioning them as the primary interposers against perceived federal overreach or unconstitutional directives. This principle of sheriff supremacy is articulated by CSPOA founder , a former , who successfully challenged the in Mack v. (1994), a case later affirmed by the Supreme Court in (1997), which ruled that the federal government cannot commandeer state or local officials to enforce federal laws. CSPOA interprets this anti-commandeering doctrine, rooted in the Tenth Amendment's reservation of powers to the states and people, as affirming the 's independent authority to evaluate and refuse enforcement of federal mandates deemed violative of constitutional limits. Mack has described the as "America's last hope," capable of arresting federal agents who enter the county without permission or who violate citizens' rights, thereby restoring a system of checks and balances at the county level. Historically, CSPOA draws on common-law traditions predating the U.S. Constitution, where English sheriffs served as the king's representatives but evolved in America into popularly elected guardians of local liberty, unencumbered by higher executive control. The association argues this role enables sheriffs to nullify unconstitutional acts within their domain, echoing interposition theories from the Founding era, such as those in the of 1798, without endorsing broader secessionist claims. In practice, CSPOA trains sheriffs to prioritize constitutional fidelity over federal policy, as seen in resolutions urging resistance to mandates like those under the Brady Act or certain measures, provided they conflict with enumerated rights. Critics, including legal scholars, contend that sheriff supremacy contradicts Article VI's , which establishes valid federal laws and treaties as the "supreme ," binding state officers notwithstanding contrary state provisions; however, CSPOA counters that only laws "made in Pursuance" of the qualify, rendering others void . Empirical instances of application remain limited, with no widespread judicial validation of arresting federal agents solely on discretion, though isolated standoffs—such as those involving land-use disputes in Western states—illustrate the doctrine's influence on -federal interactions. The CSPOA framework thus prioritizes local sovereignty as a bulwark against centralized power, grounded in the electorate's direct oversight of sheriffs via elections and recalls.

Constitutional and Historical Basis

The office of the sheriff traces its origins to ninth-century , where the "shire-reeve" served as the king's representative in a (or ), responsible for maintaining , collecting taxes, executing judgments, and summoning juries. This institution was carried to the American colonies, with the first appointed in in 1634, and by the time of independence, sheriffs were established in all 13 colonies as key figures in local governance and . In the United States, sheriffs evolved into elected positions enshrined in most state constitutions, granting them broad authority over , jail operations, and civil processes, independent of other local or state officials. Historically, this positioned sheriffs as primary protectors of public order at the local level, with powers derived from traditions emphasizing their role in preserving domestic tranquility without direct subordination to distant central authorities. The Constitutional Sheriffs and Peace Officers Association (CSPOA) grounds its advocacy in the assertion that county sheriffs, as elected constitutional officers, hold ultimate law enforcement authority within their jurisdictions, superseding federal agents when federal actions conflict with the U.S. Constitution. CSPOA emphasizes sheriffs' oath of office—typically swearing to "support and defend the Constitution of the United States against all enemies, foreign and domestic"—as imposing a duty to evaluate and resist enforcement of laws or orders deemed unconstitutional, prioritizing the supreme law of the land over subordinate statutes. This view draws on the Tenth Amendment, which reserves to the states or the people powers not delegated to the federal government, positioning sheriffs as state-derived officials unbound by federal overreach into local affairs. A pivotal legal foundation cited by CSPOA is the Supreme Court's decision in (1997), in which founder , then-sheriff of , was a co-plaintiff challenging provisions of the that required local chief law enforcement officers to conduct federal background checks. The Court ruled 5-4 that such federal commandeering of state and local executives violates the Tenth Amendment's anti-commandeering principle, affirming that the federal government cannot compel state officers to enforce or administer federal regulatory programs. CSPOA interprets this as affirming sheriffs' discretion to decline cooperation with unconstitutional federal directives, extending to interposition against perceived encroachments on like those related to firearms or land use. While CSPOA maintains this upholds constitutional federalism, critics argue it misapplies Printz, which prohibits forced participation but does not authorize sheriffs to obstruct valid federal law under the of Article VI.

Key Doctrines: Oath of Office and Nullification

The Constitutional Sheriffs and Peace Officers Association (CSPOA) posits that the oath of office sworn by county sheriffs constitutes a direct and supreme obligation to the U.S. Constitution and respective state constitutions, positioning sheriffs as the primary guardians of constitutional rights within their jurisdictions. According to CSPOA doctrine, this oath requires sheriffs to prioritize constitutional fidelity over any conflicting statutes, executive orders, or directives from higher levels of government, serving as the "first line of defense in preserving the Constitutional rights of a citizen." Sheriffs, as elected constitutional officers, are viewed as deriving their authority independently from the people of the county, not subordinate to federal or state agents, thereby obligating them to act as "the upholder, defender, protector and servant to the liberties of the people within the county." CSPOA interprets this oath to empower sheriffs with authority that supersedes that of federal, state, or municipal officials operating within county boundaries, enabling a form of interposition against perceived unconstitutional overreach. This includes the discretion to refuse enforcement of laws, regulations, or mandates deemed violative of constitutional principles, such as certain federal measures or orders. The association draws legal support from the U.S. Supreme Court's 1997 decision in , in which founder , then-sheriff of , was a ; the ruling affirmed the Tenth Amendment's anti-commandeering principle, prohibiting the federal government from compelling state or local officials to execute federal programs. CSPOA extends this precedent to argue that sheriffs bear a proactive duty to interpose against any "unconstitutional act" imposed by superior governments, framing it as a check-and-balance mechanism inherent to the constitutional structure. In practice, CSPOA's nullification doctrine encourages sheriffs to evaluate the constitutionality of directives independently, potentially leading to non-enforcement or active resistance, as exemplified in member sheriffs' public declarations against federal land-use policies or Second Amendment restrictions. While CSPOA maintains this aligns with founding principles and judicial precedents like Printz, critics contend it risks and undermines uniform application of law, though the association insists it upholds the oath's primacy over unauthorized encroachments. Training materials and resolutions promoted by CSPOA reinforce that sheriffs' oath-bound role precludes complicity in rights violations, even from elected superiors.

Organizational Structure and Operations

Leadership and Governance

The Constitutional Sheriffs and Peace Officers Association (CSPOA) is governed primarily through an advisory board chaired by its founder, , who serves as president of the board. Mack, a former of , from 1988 to 1997, established the organization in 2011 to educate sheriffs and peace officers on their constitutional oaths and authority. He successfully challenged the in the U.S. Supreme Court case Mack/Printz v. United States (1997), which ruled certain federal mandates on local officials unconstitutional. In November 2022, Sam Bushman assumed the role of CEO and national operations director, transitioning from his prior position within the organization while Mack retained oversight through the . Bushman, a radio host with over 20 years in and , manages day-to-day operations, including outreach and training programs. The includes active sheriffs such as Dar Leaf of (in his fifth term with 35 years of experience) and Bob Songer of (serving over eight years), alongside constitutional attorney , co-founder of the Institute on the Constitution. Additional leadership roles encompass Rick Dalton as national legislative liaison, a retired , focused on . Governance emphasizes decentralized decision-making aligned with the group's ideology of sheriff supremacy at the county level, with no publicly detailed bylaws or formal beyond the advisory board's consultative role in strategic direction. The organization operates as an educational network rather than a hierarchical entity, uniting s, peace officers, and citizen "posses" through training seminars and resources to promote constitutional enforcement. Membership is open to verified and the public, fostering voluntary alliances without mandatory dues or elected internal offices beyond the board. This structure supports the CSPOA's mission to restore constitutional governance peacefully, prioritizing oath-based accountability over centralized authority.

Membership and Training Programs

The Constitutional Sheriffs and Peace Officers Association (CSPOA) structures its membership around a "Posse" model, open to U.S. citizens, sheriffs, and peace officers who align with its emphasis on constitutional enforcement at the county level. Yearly Posse membership requires a $99 fee, with alternatives including $11 monthly payments or a $5,000 lifetime option; enrollment involves selecting a plan via the organization's website. Sheriffs and peace officers—defined as those with arrest powers—must affirm an to uphold the U.S. Constitution and their respective state constitutions as a condition of association, reflecting the group's core doctrine that county sheriffs hold ultimate authority within their jurisdictions. Members gain access to email updates from founder , webinars, merchandise such as membership cards and apparel, and priority event invitations. Membership numbers have fluctuated, with CSPOA reporting around 4,500 dues-paying members in 2017, encompassing both officers and civilians; more recent estimates indicate approximately 400 sheriff affiliates out of roughly 3,000 nationwide elected sheriffs. The Posse serves as a support network, enabling civilians to collaborate with sheriffs on local initiatives, while officer members receive resources to operationalize constitutional priorities. CSPOA's training programs center on educating participants in , sheriff powers, and resistance to perceived federal overreach, with a flagship offering being a six-week online certification course designed by . Priced at $195 and open to all without prerequisite membership, the self-paced program features pre-recorded lessons on U.S. constitutional interpretation, the proper role of government, and practical strategies for citizens and officers to restore liberty, including templates for sheriff engagement. Completion yields a CSPOA certification, emphasizing application over academic credentials. In addition to online modules, CSPOA organizes in-person seminars and events for sheriffs and peace officers, covering topics such as obligations, interposition against unconstitutional acts, and issue-specific guidance on Second Amendment rights and public health mandates. These sessions, sometimes held in coordination with state groups, have historically qualified for credits through bodies like Peace Officer Standards and Training (POST) commissions in states including and prior to 2023 restrictions. The programs aim to equip participants with tools for jurisdictional enforcement, drawing from Mack's legal precedents like Mack/ (1997).

Advocacy and Activities

Resistance to Federal Overreach

The Constitutional Sheriffs and Peace Officers Association (CSPOA) advocates for county sheriffs to exercise supremacy within their jurisdictions by refusing to enforce federal laws, regulations, or orders deemed unconstitutional, positioning sheriffs as a check against federal authority. This stance draws from the 1997 decision in , where CSPOA founder served as a plaintiff; the ruling held that the federal government cannot compel state or local officials to implement or enforce federal regulatory programs, such as background checks under the . CSPOA interprets this as affirming sheriffs' duty to interpose between citizens and federal overreach, including by directing deputies not to assist federal agents in actions violating constitutional rights. In practice, CSPOA member sheriffs have applied this doctrine to resist federal directives on public health and firearms. During the , over 550 sheriffs nationwide, many aligned with CSPOA principles, publicly refused to enforce federal or state mask, lockdown, or vaccination mandates, arguing they infringed on individual liberties protected by the . For instance, in , all 67 county sheriffs declined to implement such restrictions, aligning with state leadership to prioritize local discretion over federal guidance from agencies like the CDC. Similarly, in response to proposed federal gun control measures under the Obama administration in 2013, dozens of CSPOA-affiliated sheriffs signed resolutions pledging not to enforce executive actions on firearms confiscation or registration, citing Second Amendment supremacy. CSPOA has also supported resistance in federal land management disputes, exemplified by Mack's involvement in the 2014 in , where he traveled to the site to advise rancher against Bureau of (BLM) enforcement of grazing fees and cattle impoundments, framing it as unconstitutional federal intrusion on property rights. The organization's 2014 resolution further declares that sheriffs may oppose federal agents attempting to enforce unconstitutional measures within county borders, emphasizing sheriffs' elected accountability to constituents over federal directives. These actions underscore CSPOA's emphasis on non-enforcement and public declarations as primary mechanisms of resistance, rather than direct confrontation, though critics from perspectives argue such selective nullification undermines uniform application of law.

Engagement with Specific Issues (e.g., Second Amendment, Elections)

The CSPOA maintains that county sheriffs possess the constitutional authority to interpose against federal infringements on the Second Amendment, prioritizing the protection of citizens' right to keep and bear arms over enforcing perceived unconstitutional regulations. In its official Statement of Positions, the organization declares the Second Amendment as both a right and a duty for of person, family, property, and liberties, rejecting the notion that Americans are presumed "unable" to exercise it without . Sheriffs are pledged to defend this right against any threats, including opposition to universal background checks, which CSPOA argues violate the Fourth Amendment by enabling gun owner registries that risk confiscation and fail to curb violence from illicit sources like theft or black markets. Affiliated sheriffs have issued declarations refusing to enforce specific federal gun rules, such as the ATF's 2023 pistol brace regulation, with CSPOA-affiliated stating they will not "be pitted against the Second Amendment rights of law-abiding Americans" and lack authority to seize protected firearms. Examples include the Sheriffs' Association's 2021 declaration upholding Second Amendment guarantees amid national debates, and support for state-level Second Amendment Preservation Acts, like Missouri's, which nullify federal gun laws within county jurisdictions. In 2023, CSPOA highlighted and sheriffs' resistance to overreach in gun cases, framing such actions as oath-bound duties to prevent erosion of enumerated rights. On elections, CSPOA positions sheriffs as ultimate enforcers of integrity at the local level, calling for investigations into alleged 2020 presidential election fraud based on evidence like geolocation data in the 2022 documentary 2000 Mules by Dinesh D’Souza, which purportedly shows ballot harvesting irregularities. A May 24, 2022, press release demanded nationwide probes by law enforcement, emphasizing "truth-seeking" and accountability regardless of outcomes, with phrases like "Law Enforcement has to step in at this point" attributed to D’Souza and endorsed by the group. Member sheriffs, such as Yuma County's Leon Wilmot, Douglas County's Tony Home, and others, have launched jurisdiction-specific inquiries into absentee ballot fraud and chain-of-custody issues, partnering with groups like True the Vote for audits and data analysis. CSPOA frames engagement as an extension of sheriffs' supremacy in affairs, urging resistance to state or federal directives that undermine verifiable voting processes, such as expanded mail-in systems vulnerable to manipulation. The organization has hosted events and issued open invitations for sheriffs to "take back" oversight, warning of persistent risks into subsequent cycles without prosecutions or reforms. These efforts align with broader advocacy for sheriffs to nullify non-compliant administration, though outcomes of investigations have varied, with some yielding no charges due to evidentiary thresholds.

Reception and Impact

Achievements and Positive Outcomes

The Constitutional Sheriffs and Peace Officers Association (CSPOA) has contributed to legal precedents affirming the independence of local law enforcement from federal mandates. Founder , as Graham County Sheriff, was a lead plaintiff in Printz v. United States (1997), where the U.S. ruled 5-4 that the federal government cannot compel state or local officials to perform background checks under the , establishing the anti-commandeering doctrine under the Tenth Amendment. This outcome protected county-level autonomy and has been cited in subsequent challenges to federal overreach, enabling sheriffs to prioritize constitutional enforcement over delegated federal duties. CSPOA's advocacy has supported instances of sheriffs deterring federal actions perceived as infringing on property rights. In 1997, the , sheriff warned federal agents of arrest if they proceeded with cattle confiscation from rancher Wayne Hage, resulting in the animals remaining with the owner without further escalation. Similarly, sheriffs adopted a policy requiring federal agents to coordinate arrests, service of papers, or property seizures with local authorities, which has operated as an effective check without disrupting federal operations or endangering citizens. These cases illustrate practical applications of sheriff supremacy, fostering local resolution over federal intervention. Through training programs, CSPOA has expanded its influence, conducting seminars for that emphasize oath-bound duties. In 2021 alone, CSPOA trained approximately 75 sheriffs and chief deputies, alongside 250 other local officials, often qualifying for credits; founder Mack participated in 72 events across 27 states, including a three-month bus tour reaching over 20 states. This education has correlated with growing sheriff commitments to non-enforcement of federal gun regulations deemed unconstitutional, as seen in pledges by hundreds of sheriffs nationwide following 2013-2014 federal measures, preserving Second Amendment protections in rural jurisdictions without reported increases in crime. Additionally, affiliated posses, such as in , have provided volunteer services saving taxpayers roughly $500,000 annually in operational costs.

Criticisms from Opponents

Opponents, including organizations such as the (ADL) and the (SPLC), have designated the Constitutional Sheriffs and Peace Officers Association (CSPOA) as an anti-government extremist group, arguing that its doctrines encourage sheriffs to prioritize personal interpretations of the over federal and state laws, potentially fostering and undermining the . The ADL specifically contends that CSPOA's core claim—that county sheriffs hold supreme authority to nullify any law they deem unconstitutional—lacks historical or legal foundation and serves to delegitimize federal authority, with founder Richard Mack's advocacy traced to influences like the 1992 , which extremists often cite to justify resistance against government. Critics from watchdog groups like American Oversight warn that CSPOA's ideology poses a threat to democratic processes, particularly through its involvement in denialism and potential for ; for instance, as of 2023, CSPOA-affiliated sheriffs have publicly questioned the 2020 presidential results and positioned themselves to monitor or intervene in , raising concerns about of laws based on ideological alignment rather than impartial duty. Legal scholars, including those cited in analyses by , assert that the movement's nullification theory has no grounding in U.S. constitutional precedent, echoing discredited states' rights arguments from the Civil War era and risking fragmented that prioritizes local biases over national uniformity. Additional criticisms highlight perceived ties to far-right networks, with outlets like linking CSPOA's growth to broader currents of rural resentment, gun rights absolutism, and associations with white supremacist rhetoric, though such claims often stem from progressive-leaning media and advocacy groups known for expansive definitions of that encompass mainstream conservative views on . Reports from Wired and the note instances where CSPOA leaders, including Mack, have collaborated with figures from groups like the —convicted in connection with the , 2021, Capitol events—fueling accusations that the association normalizes anti-federal militancy under the guise of oath-keeping. Despite CSPOA's disavowals of ongoing Oath Keepers ties post-2011, opponents argue that Mack's historical involvement and continued platforming of similar ideologies erode public trust in impartiality.

Controversies and Debates

Alleged Ties to Extremism

Critics, including organizations such as the (ADL) and the (SPLC), have alleged that the Constitutional Sheriffs and Peace Officers Association (CSPOA) promotes anti-government extremism by advancing ideologies overlapping with sovereign citizen and movements. These groups claim CSPOA's core doctrine—that county sheriffs hold supreme authority to nullify federal laws deemed unconstitutional—mirrors sovereign citizen pseudolegal theories, potentially encouraging resistance to federal authority. For instance, the 's 2021 report highlights CSPOA founder Richard Mack's historical associations with , a group involved in the , 2021, Capitol riot, and notes Mack's appearances at events attended by sovereign citizen adherents. Mack, a former sheriff of , has publicly endorsed concepts like county supremacy, stating in 2014 that sheriffs should form an "army" to resist federal overreach on issues such as and land management. The SPLC has documented CSPOA's outreach to , including training sessions that allegedly recruit officers into these views, with some staff and members having documented sovereign citizen ties. In 2023, the Commission on banned CSPOA trainings after determining they promoted extremist ideologies incompatible with state standards. Critics further point to CSPOA's partnerships, such as with on , as amplifying unsubstantiated claims of fraud that align with broader anti-government narratives. CSPOA and Mack have rejected these characterizations, asserting that their teachings emphasize sheriffs' oaths to the U.S. Constitution rather than or violence. In a 2023 response to , Mack dismissed accusations from the Institute for Research and Education on Human Rights as "lies and false accusations," inviting scrutiny of their events and framing CSPOA's mission as defending liberty against federal encroachment. The organization maintains no formal affiliations with designated extremist groups and reports over 4,000 members, primarily elected sheriffs, focused on constitutional education without advocating unlawful actions. While no CSPOA members have been federally prosecuted for terrorism-related activities as of 2025, the allegations persist amid concerns over the group's growth, with monitors warning of potential erosion of federal authority in rural areas. Both ADL and SPLC, which track domestic , have drawn criticism for expansive definitions that encompass conservative , potentially inflating threat assessments. The Constitutional Sheriffs and Peace Officers Association (CSPOA) draws its primary legal defense from the U.S. Supreme Court's 1997 ruling in , 521 U.S. 898, which consolidated challenges brought by CSPOA founder and Montana sheriff Jay Printz against interim provisions of the of 1993. The Court held, in a 5-4 decision, that Congress cannot compel state and local officers to perform federal regulatory functions, such as s for firearm purchases, as this violates the Tenth Amendment's anti-commandeering principle by undermining state sovereignty. Mack, as Graham County Sheriff in , argued that the Act imposed unconstitutional duties on chief local officers, exposing them to federal penalties for non-compliance; the ruling invalidated those provisions while leaving the Act's national system intact. CSPOA cites this precedent to assert that sheriffs, sworn to uphold the U.S. Constitution above conflicting statutes, hold ultimate authority within their jurisdictions to evaluate and resist federal mandates deemed unconstitutional, positioning county as a check against federal overreach. This interpretation extends the Printz holding beyond to broader claims of sheriff supremacy, though courts have not universally endorsed such expansive interposition powers, emphasizing that remains supreme under Article VI unless ruled invalid. Direct legal challenges to CSPOA as an organization are limited, with no major federal lawsuits successfully curtailing its operations or core advocacy as of 2025; critics, including the and , have labeled its ideology as anti-government extremism warranting monitoring, but these assessments lack judicial enforcement. Individual member sheriffs have encountered administrative pushback, such as the Commission on barring CSPOA from providing certified training in 2022 due to concerns over its teachings conflicting with state standards on federal authority. In response, CSPOA and aligned sheriffs defend actions like refusing enforcement of certain state or federal laws—e.g., sheriffs' 2023 declarations against the Protect Illinois Communities Act's assault weapons restrictions—by invoking Tenth Amendment protections and their constitutional oath, arguing such stances prevent unlawful delegation of local duties. Opponents contend that CSPOA's framework risks nullification doctrines rejected since the early republic, potentially violating the Supremacy Clause, as seen in federal court invalidations of state laws echoing "constitutional sheriff" nullification, like Missouri's Second Amendment Preservation Act struck down in 2024 for attempting to void federal firearm regulations. CSPOA counters these critiques by distinguishing non-enforcement from active obstruction, maintaining that sheriffs' discretion aligns with Printz's preservation of dual sovereignty, a position reinforced in subsequent rulings like Murphy v. NCAA (2018), which reaffirmed anti-commandeering limits on federal coercion of states. No convictions of CSPOA members for ideology-driven refusals to enforce federal law have been reported, underscoring the practical resilience of their defenses under current jurisprudence.

References

  1. https://cspoa.org/about/
  2. https://cspoa.org/about/sheriff-mack/
  3. https://www.kslegislature.gov/li_2024/b2023_24/committees/ctte_h_fed_st_1/documents/testimony/20240307_14.pdf
  4. https://cspoa.org/
  5. https://cspoa.org/join
  6. https://azcir.org/news/2023/08/21/constitutional-sheriff-law-enforcement-training-spreads-nationwide/
  7. https://cspoa.org/cspoa-press-intro/
  8. https://www.adl.org/resources/report/constitutional-sheriffs-and-peace-officers-association-cspoa-and-richard-mack-how
  9. https://cspoa.org/support-center/what-is-the-cspoa/
  10. https://www.countysheriffproject.org/CSPOA_Invitation_Dec29.2011.pdf
  11. https://www.adl.org/sites/default/files/CSPOA%2520Backgrounder%2520FINAL.pdf
  12. https://www.vice.com/en/article/richard-mack-constitutional-sheriff-movement/
  13. https://www.splcenter.org/resources/extremist-files/constitutional-sheriffs/
  14. https://cspoa.org/cspoa-2021-accomplishments/
  15. https://www.texastribune.org/2023/01/13/constitutional-sheriffs-texas/
  16. https://www.asisonline.org/security-management-magazine/latest-news/today-in-security/2023/august/influence-of-CSPOA-increasing/
  17. https://www.newstribune.com/news/2023/aug/22/sheriffs-group-that-challenges-federal-law-gains/
  18. https://cspoa.org/get-the-cspoa-certification-course/
  19. https://www.rollingstone.com/politics/politics-features/constitutional-sheriffs-far-right-movement-1235103658/
  20. https://mydakotan.com/2025/07/roise-hosts-constitutional-rally-with-richard-mack-pushes-posse-style-policing/
  21. https://cspoa.org/press-releases/
  22. https://law.justia.com/cases/federal/district-courts/FSupp/856/1372/1680892/
  23. https://www.politico.com/magazine/story/2017/09/01/joe-arpaio-pardon-sheriffs-movement-215566
  24. https://cspoa.org/wp-content/uploads/The_Victory_For_State_Sovereignty.pdf
  25. https://www.hcn.org/issues/48-2/the-rise-of-the-sagebrush-sheriffs/
  26. https://www.sheriffs.org/about-nsa/history/roots
  27. https://gospercountyne.gov/sheriff-office/history-of-the-office-of-sheriff/
  28. http://www.unionsheriff.us/history.php
  29. https://www.camdencounty.com/wp-content/uploads/2017/12/History-Sheriff.pdf
  30. https://cspoa.org/wp-content/uploads/The-Stance-of-a-Constitutional-Sheriff-2021.pdf
  31. https://supreme.justia.com/cases/federal/us/521/898/
  32. https://www.oyez.org/cases/1996/95-1478
  33. https://statesunited.org/resources/factsheet-constitutional-sheriff/
  34. https://apnews.com/article/constitutional-sheriffs-5568cd0b6b27680a28de8a098ed14210
  35. https://cspoa.org/about/our-leadership/
  36. https://www.splcenter.org/resources/hatewatch/constitutional-sheriffs-association-ceo-doubles-down-hate-group-associations-south/
  37. https://cspoa.org/join/
  38. https://cspoa.org/product/lifetime-posse-membership-package/
  39. https://cspoa.org/product/membership-card-more-addition/
  40. https://cspoa.org/support-center/how-can-i-join-the-cspoa-online-posse/
  41. https://journals.law.unc.edu/nccivilrightslaw/2024/01/the-constitutional-sheriffs-and-peace-officers-association-its-north-carolina-presence-and-its-impact/
  42. https://cspoa.org/support-center/what-is-the-cspoa-online-certification-class/
  43. https://cspoa.org/events/
  44. https://cspoa.org/training-seminar-sept-30-in-va/
  45. https://cspoa.org/americas-sheriffs-hold-the-key-to-freedom-and-safety/
  46. https://www.nbcnews.com/news/investigations/no-sheriff-town-some-lawmen-refuse-enforce-federal-gun-laws-n185426
  47. https://www.youtube.com/watch?v=k63jOjxFpaA
  48. https://cspoa.org/wp-content/uploads/cspoa-resolution-Final-20140128.pdf
  49. https://cspoa.org/wp-content/uploads/cspoa-statement-of-positions.pdf
  50. https://cspoa.org/wp-content/uploads/2A-COPS-Pistol-Brace-Letter-Gun-Owners-of-America3548.pdf
  51. https://cspoa.org/latest-news/utah-sheriffs-association-2nd-amendment-declaration/
  52. https://cspoa.org/cspoa-legislative-lowdown-az-sheriffs-and-nm-state-attorney-stand-against-government-overreach-by-rick-dalton/
  53. https://cspoa.org/elections/
  54. https://www.newswire.com/news/the-cspoa-is-calling-upon-all-americans-and-law-enforcement-nationwide-21721141
  55. https://www.yumacountysheriff.org/pr-2022/PR-2022-30-Yuma-County-Voting-Fraud.pdf
  56. https://cspoa.org/wp-content/uploads/CSPOA-Press-Conference-Release-Flyer.pdf
  57. https://cspoa.org/wp-content/uploads/The_County_Sheriff_eBook.pdf
  58. https://www.spokesman.com/stories/2024/oct/11/constitutional-sheriff-raises-controversial-posses/
  59. https://americanoversight.org/investigation/the-constitutional-sheriffs-movement-and-its-threat-to-democracy/
  60. https://www.npr.org/2024/09/10/g-s1-21802/constitutional-sheriffs-wield-unchecked-power-across-america-journalist-says
  61. https://www.wired.com/story/constitutional-sheriffs-disrupt-election/
  62. https://cspoa.org/azcir-article-on-cspoa/
  63. https://www.splcenter.org/resources/hatewatch/texas-commission-bans-training-constitutional-sheriffs-group/
  64. https://cspoa.org/latest-news/sheriff-macks-response-to-attorney-general-keith-ellison-over-irehr-devin-burgharts-lies-and-false-accusations/
  65. https://cronkite.asu.edu/news/2023/howard-center-investigation-examines-increasing-influence-of-constitutional-sheriffs-group/
  66. https://www.law.cornell.edu/supct/html/95-1478.ZO.html
  67. https://cspoa.org/product/supreme-court-case-for-state-sovereignty-2/
  68. https://www.law.georgetown.edu/georgetown-law-journal/wp-content/uploads/sites/26/2025/07/Heydari_The-Sheriffs-Constitution.pdf
  69. https://www.themarshallproject.org/impact/policing-the-sheriffs
  70. https://lawecommons.luc.edu/cgi/viewcontent.cgi?article=2865&context=luclj
  71. https://www.everytown.org/press/victory-for-gun-safety-in-the-courts-eighth-circuit-upholds-federal-court-decision-striking-down-missouris-dangerous-second-amendment-preservation-act/
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