frequently refuse to pay taxes, obtain driver's licenses, or comply with regulatory authorities. They deny the validity of United States fiat money because it is not backed by gold, which they claim the Constitution requires. They draw up unusual legal documents and attempt to record them, they declare their independence from the United States, or they claim to file "common law" liens against their perceived enemies such as Internal Revenue Service employees or judges. They are frequently involved in various tax protests, and they have invoked ideas that have been popularized by tax protesters. Criminal activities The Posse Comitatus made national news when, on February 13, 1983, Posse member Gordon Kahl killed two federal marshals who had come to arrest him in North Dakota and became a fugitive. Another shootout ensued on June 3, 1983, in which Kahl and Lawrence County, Arkansas, Sheriff Gene Matthews were killed. Other members of the group have also been convicted of crimes ranging from tax evasion and counterfeiting to threatening the lives of IRS agents and judges. The organization also demonstrated support for its members over other issues. On September 2, 1975, Francis Earl Gillings, the founder of a San Joaquin County Posse group, led a group of armed Posse members to prevent United Farm Workers union organizers from attempting to organize non-union tomato pickers. As sheriff's deputies attempted to arrest Gillings on a traffic warrant, one got into a scuffle with Gillings, and a shot was fired. On August 15, 2012, five suspects were arrested concerning the fatal shooting of two sheriff's deputies and wounding two others in St. John the Baptist Parish, Louisiana. Terry Smith, 44; Brian Smith, 24; Derrick Smith, 22; Teniecha Bright, 21; and Kyle David Joekel, 28, were identified, with Brian Smith and Joekel identified as the shooters in the incident. The men are rumored to be affiliated with a Posse Comitatus group. On August 17, 2012, two more suspects—Chanel Skains, 37, and Britney Keith, 23—were charged with accessory after the fact. Legacy Christian Patriot movement The direct ideological descendants of the Posse Comitatus movement were found in the "Christian Patriot" branch of the Patriot movement. Most Christian Patriot groups adhere to Christian Identity's white supremacist views and the Posse Comitatus' view that the American government had deprived citizens of their natural "common law" rights. They have notably espoused Gale's concept of "individual sovereignty", which developed into the broader