Well, his first appearance as our foe was in a dungeon well outside of any meaningful jurisdiction, and his second was in the middle of a hobgoblin army, so he's been pretty well out of any kingdom's reach without an army. And to be honest... he's an epic-level sorcerer. Armies aren't much either. Nor are heroes. I hate to admit it, but I think I'm still the highest-level good character on the field -- or close, after the resurrection level loss -- and he's still a dozen higher.