Still’s lawyers argued in court filings, “In that role, Mr. Still was, or was acting under, an officer of the United States.”
[. . .]
At another point in her Sept. 5 brief, Willis explained “Impersonating certified presidential electors in service to a political campaign cannot be seriously within the scope of any federal role.”
In short, he claimed he was acting as a federal officer, but the courts pointed out that pretending to be a federal officer does not actually make you one.