On May 30, 2006, the U.S. 7th Circuit Court of Appeals upheld Matt Hale's 2004 conviction and 40-year sentence for soliciting the murder of U.S. District Judge Joan Lefkow. Lefkow had ordered Hale's white supremacist group to stop using the name World Church of the Creator in a trademark infringement case, causing Hale to become enraged, according to evidence presented at the trial. Hale tried to persuade FBI informant Anthony Evola, head of Hale's security force, to kill Judge Lefkow.
At one time Hale was one of the most prominent far-right leaders. Since his incarceration, his group, the Creativity Movement, has dwindled into insignificance. Many of its members have joined other groups, and there is no discernible leadership.