Gerald Mayo, a 22-year-old inmate at Western Penitentiary in Pittsburgh, Pennsylvania,[3] filed a claim before the United States District Court for the Western District of Pennsylvania in which he alleged that "Satan has on numerous occasions caused plaintiff misery and unwarranted threats, against the will of plaintiff, that Satan has placed deliberate obstacles in his path and has caused plaintiff's downfall" and had therefore "deprived him of his constitutional rights" in violation of the United States Code.

Additionally, while no previous cases had been brought by or against Satan and no official precedent existed, the court jokingly remarked that there was an "unofficial account of a trial in New Hampshire where this defendant filed an action of mortgage foreclosure as plaintiff," a reference to the 1936 short story "The Devil and Daniel Webster" by Stephen Vincent Benét.

The court suggested that the Devil, who had claimed in that story to be an American, should he have appeared, might have been therefore stopped from arguing a lack of personal jurisdiction.

In this context, the court noted that Satan was a foreign prince, but did not have occasion to address whether, if sued as a defendant, he would be able to claim sovereign immunity from suit.

Pa. 1971), the court dismissed the case because the plaintiff failed to render such aid when asking the marshal to serve the devil himself.