IN THE UNI TED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLI NA CHARLESTON DIVISION UNI TED STATES OF AMERICA CR. NO.: 18 18 18 18 18 18 18 18 18 V. DYLANN STORM ROOF u .s.c. u.s.c. u.s.c. u.s.c. u.s.c. u.s . c . u.s.c. u.s.c. u.s.c. § § § § § § § § § 249(a) 247 (a) 247 (d) 247{d) 92 4 {c) 924 (c) 924 ( j) 3591 3592 (1) (2) (1) (3) (1) (A) (1) (C) INDICTMENT THE GRAND JURY CHARGES: 1. Defendant DYLANN STORM ROOF is a wh ite male who, on June 17, 2015, was twenty-one years old. 2. In April 2015, Defendant purchased a Glock, model 41, 3. DYLANN because In the STORM of months ROOF their before June to He African-American worshipers STORM ROOF .45 caliber pistol . decided race. DYLANN 17, attack further 2015, Defendant African- Ame ricans decided to attack in an African-American church in order to make his attack more notorious . 4. Prior to June 17, 2015, Defendant ROOF obtained and used the website 1 DYLANN STORM lastrhodesian. com. He placed on that expressing his website racist a manuscript beliefs. and photographs In the manuscript, DYLANN STORM ROOF uses racial slurs to describe African-Americans, expresses his belief that white people are superior to African-Americans, and decries integration. The photographs on lastrhodesian . com include DYLANN STORM ROOF wearing a jacket with flags of two former apartheid African nations, displaying his Glock .45 caliber pistol, and holding a confederate flag. On the evening of June 17, 2015, 5. Defendant DYLANN STORM ROOF drove to the Emanuel African Methodist Episcopal Church (AME) in Charleston, South Carolina, commonly referred to as "Mother Emanuel," to attack African-American parishioners engaged in religious activities. He selected Emanuel AME Church because it had a predominately AfricanAmerican membership, and because it was significant to the people of Charleston, of South Carolina, and of the Nation. 6. Defendant tensions perceived By attacking DYLANN across STORM the wrongs African-American ROOF Nation, he wanted and believed committed against white people. 2 to sought parishioners, increase racial retribution African-Americans for had 7. On the evening of June 17, 2015, African-American parishioners at Emanuel AME Church were participating in a religious Clementa worship and Bible Pinckney (a study group led by Reverend forty-one-year-old African-American man) and attended by Reverend Sharonda Coleman-Singleton (a forty-five-year-old (a African-American fifty-four-year-old Jackson Ethel woman), African-American woman), Reverend K .M. Lance (an year-old seventy-year-old (a eleven-year-old DePayne African-American Middleton-Doctor woman) , Felicia African-American Sr. (a (a Sanders woman) , girl), forty-nine-year-old (a Tywanza seventy-four-year-old Polly Sheppard woman), Susie African-American African-American twenty-six-year-old African-American man), man) , woman), Hurd (an eighty- seven-year-old African-American woman) , Lee Simmons, Cynthia fifty-eight Sanders (a Reverend Daniel African-American (a seventy-year-old African-American and Myra Thompson (a fifty-nine-year-old African- American woman) . 8. On the evening of June 17, 2015, Defendant DYLANN STORM ROOF entered Emanuel AME Church with his Glock, model 41, .45 caliber pistol hollow-point bullets, and eight magazines loaded with with the intent of killing African3 Americans engaged . the l.Il exercise of their religious beliefs. 9. The parishioners welcomed Defendant DYLANN STORM ROOF into their Bible study group, and ROOF sat next to Reverend Clementa Pinckney. 10. While the parishioners were engaged in religious worship and Bible study, Defendant DYLANN STORM ROOF drew his pistol and opened Reverend Sharonda Jackson, Ethel Reverend Reverend Daniel attempting to on the par ishioners, Coleman-Singleton, Lee Doctor, fire Lance, Reverend Clemen ta Simmons, kill Cynthia Sr., K.M., and Felicia Hurd, DePayne Pinckney, Tywanza Myra k i lling Susie MiddletonSanders, Thompson; Sanders, and and Polly Sheppard. COUNTS 1-9 (Hate Crime Act Resulting in Death) THE GRAND JURY FURTHER CHARGES : 11. The allegations set for th in paragraphs 1 through 10 are repeated and realleged as if set forth fully herein. 12. South On o r Carolina, about June Defendant 17, 2015, DYLANN in STORM the District ROOF of wi ll fully caused bodily injury to the below-listed victims because of their actual and perceived race and color: 4 VICTIM COUNT 1 Reverend Sharonda Coleman- Singleton 2 Cynthia Hurd 3 Susie Jackson 4 Ethel Lee Lance 5 Reverend De Payne Middleton-Doctor 6 Reverend Clemen ta Pinckney 7 Tywanza Sanders 8 Reverend Daniel Simmons, Sr. 9 Myra Thompson The offenses resulted in the death of each of the victims in Counts 1 to 9. All in violation of Title 18, United States Code, Section 249 (a) (1). COUNTS 10-12 (Hate Crime Act Involving An Attempt to Kill) THE GRAND JURY FURTHER CHARGES: 13. The allegations set forth in paragraphs 1 through 10 are repeated and realleged as if set forth fully herein. 14. On or South Carolina, about June 17, 201 5 , in the Defendant DYLANN STORM ROOF, 5 District of through the use of a firearm (a Glock, mode l attempted victims to cause because of bodily their 41, injury actual . 45 caliber pistol) , to and the below-listed perceived race and of the color: COUNT The VICTIM 10 K.M. 11 Felicia Sanders 12 Polly Sheppard offenses included an attempt to kill each victims in counts 10 to 12 . All in violation of Title 18, United States Code, Section 249(a) (1). COUNTS 13-21 (Obstruction of Exercise o f Religion Res ulting in Death) THE GRAND JURY FURTHER CHARGES: 15. The allegations set forth in paragraphs 1 through 10 are repeated and realleged as if set forth fully herein. 16. On or about South Carolina, obstructed by June 17, 2015, in the District of Defendant DYLANN STORM ROOF intentionally force each victim 6 listed below in the enjoyment of that victim's free exercise of religious beliefs: COUNT The VICTIM 13 Reverend Sharonda Coleman-Singleton 14 Cynthia Hurd 15 Susie Jackson 16 Ethel Lee Lance 17 Reverend De Payne Middleton-Doctor 18 Reverend Clementa Pinckney 19 Tywanza Sanders 20 Reverend Daniel Simmons, Sr. 21 Myra Thompson acts of Defendant DYLANN STORM ROOF resulted in the death of each victim listed in Counts 13 to 21 and were in and affected interstate commerce. All in violation of Title Sections 247(a) (2) and 247 (d) (1). 7 18, United States Code, COUNTS 22-24 (Obstruction of Exercise of Religion Involving An Attempt to Kill and Use of a Dangerous Weapon) THE GRAND JURY FURTHER CHARGES: 1 7. The allegations set forth in paragraphs 1 through 10 are repeated and realleged as if set forth fully herein. 18. On or about South Carolina, June 17, 2015, in the Defendant DYLANN STORM ROOF District of intentionally obstructed by force and threat of force each victim listed below in the enjoyment of that victim's free exercise of religious beliefs, and attempted to do so: VICTIM COUNT 22 K.M. 23 Felicia Sanders 24 Polly Sheppard The acts of Defendant DYLANN STORM ROOF included an attempt to kill each of the victims in Counts 22 to 24; involved the 41, use caliber of a dangerous pistol); and weapon were (a Glock, model in and affected Title 18, United .45 interstate commerce. All in violation of Sections 247 (a) (2), 247 (d) (1), and 247 (d) (3) . 8 States Code, COUNTS 25-33 (Use o f a Firearm to Conunit Murder During and In Relation to a Crime of Violence) THE GRAND JURY FURTHER CHARGES: 19. The allegations set forth in paragraphs 1 through 10 are repeated and realleged as if set forth fully herein. 20. On or about June 1 7, 2015, in the District of South Carolina, Defendant DYLANN STORM ROOF knowingly used and discharged a firearm (Glock, model 41, .45 caliber pistol) during and in relation to a crime of violence for which he may be prosecuted in a court of the United States - violations of 18 u.s.c. § 249 as charged in Counts 1 to 9, and violations of 18 U.S . C. § 247 as charged in Counts 13 to 21 - and caused the death of each victim listed below through the use of t he fire arm in such a constitute murder as defined in 18 the Defendant, with malice u.s .c. aforethought, § manner 1111, did VICTIM 25 Reverend Sharonda Coleman-Singleton 26 Cynthia Hurd 27 Susie Jackson 9 to in that unlawfully kill each victim wi th the firearm . COUNT as All 28 Ethel Lee Lance 29 Reverend De Payne Middleton- Doctor 3 ff Reverend Cl ementa Pinckney 31 Tywanza Sanders 32 Reverend Daniel Simmons, Sr. 33 Myra Thompson in violation of Title 18, United Sections 924 (c) (1) (A), 924 (c) (1) (C), and 924 (j) States Code, (1). NOTICE OF SPECIAL FINDINGS PURSUANT TO TITLE 18 , UNITED STATES CODE, SECTIONS 3 5 91 AND 3 592 THE GRAND JURY FURTHER FINDS: 21. The allegations set forth in para9raphs 1 through 20 are repeated and real l eged as if set forth fully herein. 22. As to Counts 13-21 and 25-33, the Defendant DYLANN STORM ROOF: (a) was 18 years of age or older at the time of the offense; (b) Coleman - Singleton, Ethel Doctor, Reverend killed intentionally Cynthia Hurd, Susie Lance, Reverend DePayne Reverend Clementa Pinckney, Lee 10 Sharonda Jackson, MiddletonTywanza Sanders, Reverend Daniel Thompson (18 U . S.C . (c) Simmons, Sr. , and Myra 3591 (a) (2) (A)); § intentionally inflicted serious bodily injury that resulted in the deaths of Reverend Sharonda Coleman-Singleton, Ethe 1 Lee Cynthia Hurd, Lance, Reverend Doctor, Reverend Clemen ta Sanders, Reverend Thompson {18 Daniel u . s. c. 3 5 91 § DePayne Jackson, Middleton- Pinckney, Simmons , Sr. , Tywanza and Myra (a) ( 2) ( B} ) ; participated intentionally ( d) Susie in an act, contemplating that the life of a person would be taken force and intending that lethal used in connection with a of the participants Sharonda Jackson, person, Ethel Middleton-Doctor, Lee and Reverend Cynthia Lance, Reverend be other than one in the offense, Coleman - Singleton, would Hurd, Reverend Clemen ta Susie De Payne Pinckney, Tywanza Sanders, Reverend Daniel Simmons, Sr., and Myra Thompson died as a direct result of such act (18 U.S.C . § 359l(a) (2) (C)); (e) intentionally and specifically engaged in an act of violence, knowing 11 that the act created a grave risk of death to a person, other than one of the participants participation disregard for in in the human Coleman-Singleton, Ethel Lee the act offense, such constituted life and Cynthia a reckless Reverend Sharonda Hurd, Susie Lance, Reverend DePayne Doctor, Reverend Clemen ta Pinckney, Sanders, Reverend Daniel Thompson died as a U.S.C. ( f) § that Simmons, Jackson, MiddletonTywanza Sr. , and direct result of the Myra act ( 18 3591(a) (2) (D)); committed the offenses charged in Counts 13-21 and substantial after 25-33 planning premeditation to cause the death of a person U.S.C. (g) § ( 18 3592 (c) (9)); committed the (for and killing years old) , Susie Counts offenses Jackson 16 in Counts who and 28 was 15 and 27 eighty-seven (for killing Ethel Lee Lance, who was seventy years old), and Counts 20 and Sr. , (for killing Reverend 32 old) on victims who were particularly vulnerabl e due to old age u . s .c . § seventy- four Simmons, years ( 18 who was Daniel 3 s 9 2 ( c ) ( 11 ) ) ; and 12 (h) in committing the offenses in Counts 13-21 and 25-33, intentionally killed and attempted to kill more than one person in a single criminal episode (18 u.s.c. § 3592 (c) (16)). WILLIAM N. NETTLES (jnr) UNITED STATES ATTORNEY ATTORNEY GENERAL CIVIL RIGHTS DIVISION 13 UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION UNITED STATES OF AMERICA § s ~ v. ss CRIMINAL NO. s ~ s~ s ~ DYLANN ROOF CERTIFICATE OF THE ATTORNEY GENERAL I, Loretta E. Lynch, hereby certify that in my judgment, prosecution by the United States of Dylann Roof for violating Title 18, United States Code,§ 249(a){l), is in the public interest and is necessary to secure substantial justice and the state lacks jurisdiction to bring a hate crime prosecution. This certification is made pursuant to Title 18, United States Code,§ 249 . .[ ...< Signed this 1.t' '-·day of~, 2015 . . oretta F. Lynch Attorney General UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION UNITED STATES OF AMERICA § § V. § § § DYLANNROOF CRIMINAL NO. § CERTIFICATE OF THE ATTORNEY GENERAL I, Loretta E. Lynch, hereby certify that in my judgment, prosecution by the United States ofDylann Roof for violating Title 18, United States Code, § 247(a)(2), is in the public interest and is necessary to secure substantial justice. This certification is made pursuant to Title 18, United States Code, § 247 (e). Signed this J.c "'--day of July, 2015. Loretta E. Lynch Attorney General