TUB I.INITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF PENNSYLVANIA
N'I

UNITED STATES OF AMERICA
v
ROBERT BOWERS

)
)
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)
)
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Criminal No. 18-292
(18

u.s.c.

$$ 247@)(2),247(d)(r),
(3), 2 ae @) (1) (B) o, 2ae @)( 1 XBXii),
e2a(c)( 1 )(A)(i), e2a(c)( 1 XAXii),
e2a(c)(1 )(A)(iii), and 924(j)0))
2

47 (d)

SUPERSEDING INDICTMENT
The grandjury charges

1.

At all times

relevant

to the

Superseding Indictment, the defendant, ROBERT

BOWERS, was a resident of Allegheny County in the Western District of Pennsylvania.

.2.

Prior to October 27,2018, the defendant, ROBERT BOWERS, created an account

on the website gab.com. The account for the defendant, ROBERT BOWERS, included a statement

on his profile expressing the belief that 'Jews are the children of satan," as well as several posts
that referred to Jewish people using anti-Semitic slurs.

3.

On or about October 10, 2018, the defendant, ROBERT BOWERS, posted on

gab.com a criticism of the Hebrew Immigrant Aid Society (HIAS) and a link to a HIAS webpage

listing Jewish congregations that were hosting refugee-related events. That list of congregations
included the Dor Hadash Jewish congregation of Pittsburgh. In the posting, the defendant,
ROBERT BOWERS, wrote, "Why hello there HIAS! You like to bring in hostile invaders to dwell
among us? We appreciate the list of friends you have provided[.]"

4.

On the morning of October 27,2018, the defendant, ROBERT BOWERS, drove to

the Tree of Life Synagogue ("the Synagogue"), located at 5898 Wilkins Avenue, Pittsburgh,
Perursylvania. The Synagogue building houses three Jewish congregations, to include the Tree

of

 Life, Dor Hadash, and New Light congregations.

5.

Before entering the Tree of Life Synagogue, the defendant, ROBERT BOWERS,

posted bn gab.com, *HIAS likes to bring invaders in that

kill our people. I can't sit by and watch

my people get slaughtered. Screw your optics, I'm going in."

6.

At that time, members of the Tree of Life, Dor Hadash,

and New Light

congregations had gathered to engage in religious worship at the Tree of Life Synagogue and were
already present within the building. Additional congregants were arriving at the Tree of Life
Synagogue to engage in religious worship.

7.

As he approached the building carrying multiple firearms, the defendant, ROBERT

BOWERS, shot at and shattered a large window on the Synagogue's fagade, near the entrance.
The defendant, ROBERT BOWERS, then entered the Tree of Life Synagogue.

8.

While inside the Synagogue, the defendant, ROBERT BOWERS, opened fire,

killing and injuring members of the Tree of Life, Dor Hadash,

g.

and New

Light congregations.

The defendant, ROBERT BOWERS, also fired at responding public safety officers,

injuring patrol officers outside the Tree of Life Synagogue as they approached the building. In
addition, after Pittsburgh SWAT operators entered the Synagogue, and while they were attempting

to rescue surviving victims and to locate the shooter, the defendant, ROBERT BOWERS, opened

fire on the SWAT operators, injuring several of them.

10.

While inside the Tree of Life Synagogue, the defendant, ROBERT BOWERS,

made statements conveying his anti-Semitic beliefs and indicating his desire to
1

as

1.

Paragraphs

I through

"kill Jews."

10 of this Superseding Indictment are hereby reincorporated

to all Counts charged below.

2

 COUNTS ONE THROUGH ELEVEN
(Obstruction of Free Exercise of Religious Beliefs Resulting in Death)
The grand jury further charges:

On or about October 27,2018, in the Western District of Pennsylvania, the defendant,
ROBERT BOWERS, intentionally obstructed by force each victim listed below in the enjoyment
of that victim's free exercise of religious beliefs:

COUNT

VICTIM

1

J.F.

2
J

R.G
R.M.

4

J.R.

5

C.R.
D.R.
B.S

6
7
8

S.S

9
10

D.S

M.W
I.Y

11

The acts of the defendant, ROBERT BOWERS, resulted in the death of each victim listed in
Counts One through Eleven, and the offense was in and affected interstate commerce.

All in violation of Title

18, United States Code, Sections 2a7@)Q)

J

and2a7@)(l).

 COUNTS TWELVE THROUGH TWENTY-TWO
(Hate Crime Act Resulting in Death)
The grand jury further charges:

On or about October 27, 2018, in the Westem District of Pennsylvania, the defendant,
ROBERT BOWERS, willfully caused bodily injury to each victim listed below because of that

victim's actual and perceived religion:
COUNT
t2

VICTIM
J.F

t4

R.G
R.M.

13
15

J.R.

16
17
18

C.R.
D.R.
B.S.

t9

S.S

20

D.S

2t

M.W
I.Y.

22

The offenses resulted in the death of each victim listed in Counts Twelve through Twenty-Two
A1l in violation of Title 18, United States Code, Section 2a9(aX1)(BXi).

4

 COUNTS TWENTY.THREE THROUGH THIRTY-THREE
(Use and Discharge of a Firearm to Commit Murder During and in Relation to a
Crime of Violence and Possession of a Firearm in Furtherance of a Crime of Violence)
The grand jury further charges:

On or about October 27, 2018, in the Western District of Pennsylvania, the defendant,
ROBERT BOWERS, did knowingly use, carry, brandish, and discharge a firearm, to wit, 1) a

Glock .357 handgun, bearing serial number BCUM029;2) a Glock .357 handgun, bearing serial
number YEY449;3) a Glock .357 handgun, bearing serial number RHY244; and 4) a Colt AR-15

rifle, model SPl, bearing serial number SP99907, during and in relation to a crime of violence for
which he may be prosecuted in a court of the United States, that is, violations of 18 U.S.C . 5 247
as charged

in Counts One through Eleven, and violations of Title 18, United States Code, Section

249, as charged in Counts Twelve through Twenty-Two of this Superseding Indictment, and did

knowingly and unlawfully possess a firearm in furtherance of said crimes of violence, as to each

victim set forth below, and did cause the death of each victim listed below through the use of

a

firearm in such a manner as to constitute murder as defined in 18 U.S.C. $ 1111(a), in that the
defendant, ROBERT BOWERS, with malice aforethought, did unlawfully

kill

each victim with a

firearm.

COUNT

CORRESPONDING CRIME
OF'VIOLENCE BY COIJNTS

VICTIM

23

I

24

2 and 13
3 and 14

R.G
R.M.

4 and 15
5 and 16
6 and 17
7 and 18
8 and 19
9 and20
l0 and 21
and22

J.R.

25

26
27
28
29
30
31

)Z
JJ

J.F

and 12

C.R.
D.R.
B.S
S.S.

D.S.

M.W.
I.Y.

ll

All in violation of Title 18, United States Code, Sections 92a@)Q)(1t)(t),92a@)(1)(AXii),
e2a(c)(1

)(A)(iii), and e24fi)(t).
5

 COUNTS THIRTY.FOUR AND THIRTY.FIVE
(Obstruction of Free Exercise of Religious Beliefs Involving an
Attempt to KilI and Use of a Dangerous Weapon, and Resulting in Bodily Injury)
The grand jury further charges:

On or about October 27,2018, in the Western District of Pennsylvania, the defendant,

ROBERT BOWERS, 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:

COUNT

VICTIM

34

D.L.
A.W

35

The acts of the defendant, ROBERT BOWERS, included an attempt to kill each vietim listed in
Counts Thirty-Four and Thirty-Five; and resulted in bodily injury to each victim listed in Counts

Thirty-Four and Thirty-Five; such acts also included the use, attempted use, and threatened use

of

a dangerous weapon, to wit, 1) a Glock .357 handgun, bearing serial number BCUM029;2) a

Glock.357 handgun, bearing serial numberYEY44g;3) a Glock.357 handgun, bearing serial
number RtlY244; and 4) a Colt AR-15 rifle, model SPl, bearing serial number SP99907; and the
offense was in and affected interstate coflrmerce.

All in violation of Title 18, United States Code, Sections 247(a)(2), 247(d)(l),
247(d)(3).

6

and

 COUNTS THIRTY-SIX AND THIRTY.SEVEN
(Hate Crime Act Involving an Attempt to Kitl)
The grandjury further charges:

On or about October 27, 2018, in the Westem District of Pennsylvania, the defendant,
l

ROBERT BOWERS, willfully caused bodily injury to each victim listed below because of that

victim's actual and perceived religion:
COUNT

VICTIM
D.L.
A.W.

36
37

The offenses included an attempt to kill each victim listed in Counts Thirty-Six and Thirty-Seven.

All in violation of Title 18, United

States Code, Section 2a9(a)(1)(B)(ii).

7

 COUNTS THIRTY-EIGHT AND THIRTY.NINE
(Use and Discharge of a Firearm During and in Relation to a Crime of Violence and
Possession of a Firearm in Furtherance of a Crime of Violence)
The grand jury further charges:

On or about October 27,2018, in the Western District of Pennsylvania, the defendant,
ROBERT BOWERS, did knowingly use, caffy, brandish, and discharge a firearm, to wit,

l)

a

Glock .357 handgun, bearing serial number BCUM029;2) a Glock .357 handgun, bearing serial
number YEY449;3) a Glock .357 handgun, bearing serial numb erRI1Y244; and 4) a Colt AR-15

rifle, model SP1, bearing serial number SP99907, during and in relation to a crime of violence for
which he may be prosecuted in a court of the United States, that is, violations of 18 U.S.C.
as charged

S 247

in Counts Thirty-Four and Thirty-Five, and violations of Title 18, United States Code,

Section 249, as charged at Counts Thirty-Six and Thirty-Seven of this Superseding Indictment,
and did knowingly and unlawfully possess a firearm in furtherance of said crimes of violence, as

to each victim listed below.

COUNT
38

39

All inviolationofTitle

CORRESPONDING CRIME
OF VIOLENCE BY COUNTS
34 and36
35 ard37
18, United States Code, Sections

and924(c)(lXAXiii).

8

VICTIM
D.L.

A.W

924(c)(1)(A)(i),92a@)(lXAXii),

 COUNTS FORIY THROUGH FORTY.SEVEN
(Obstruction of Free Exercise of Religious Beliefs Involving an Attempt to Kill and
Use of a I)angerous Weapon, and Resulting in Bodily Injury to a Public Safety Officer)
The grand jury further charges:

On or about October 27, 2018, in the Western District of Pennsylvania, the defendant,

ROBERT BOWERS, 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:

COUNT

VICTIM

44

C.B.
J.C.
M.G.
A.G.
J.M.

45

J.P

46
47

B.W.

40

4l
42
43

s.w.

The acts of the defendant, ROBERT BOWERS, included an attempt to

kill

each

victim listed in

Counts Forty through Forty-Seven; such acts also included the use, attempted use, and threatened
use of a dangerous weapon, to

wit, 1) a Glock .357 handgun, bearing serial number BCUM029;2)

a Glock .357 handgun, bearing serial number YEY449; 3) a Glock .357 handgun, bearing serial
number RI1Y244;and 4) a Colt AR-15 rifle, model SPl, bearing serial number SP99907; and such
acts resulted in

bodily injury to A.B., T.M., D.M., J.P., and M.S., public safety offtcers who were

then performing duties as a direct and proximate result of the defendant's conduct as charged in

Courts Forty through Forty-Seven; and the offense was in and affected interstate cofiImerce.

All in violation gf Title 18, United States Code, Sections 247(a)(2), 247(d)(t), and
247(d)(3).

9

 COUNTS FORTY-EIGHT THROUGH FIFTY.ONE
(Obstruction of Free Exercise of Religious Beliefs Involving
Use of a Dangerous Weapon and Resulting in Bodily Injury to a Public Safety Officer)
The grand jury further charges:

On or about October 27, 2018, in the Western District of Pennsylvania, the defendant,
ROBERT BOWERS, 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:

COUNT

VICTIM

48
49
50

D.D
L.F

51

J.S.

D.R.2

The acts of the defendant, ROBERT BOWERS, included the use, attempted use, and threatened
use of a dangerous weapon, to

wit:

1) a Glock .357 handgun, bearing serial mrmber

BCUMO29;2)

a Glock .357 handgun, bearing serial numberYEY449; 3) a Glock .357 handgun, bearing serial

number RIIY244; and 4) a Colt AR-15 rifle, model SP1, bearing serial number SP99907; and such
acts resulted in bodily injury to A.B., T.M., D.M., J.P., and M.S., public safety officers who were

then performing duties as a direct and proximate result of the defendant's conduct as charged in
Counts Forty-Eight through Fifty-One; and the offense was in and affected interstate commerce.

AII in violation of Title 18, United States Code, Sections 2a7@)(2) and2a7@)(3).

10

 COUNTS FIFTY-TWO THROUGH SIXTY-THREE
(Use and Discharge of a Firearm During and in Relation to a Crime of Violence"and
Possession of a Firearm in Furtherance of a Crime of Violence)
The grand jury further charges:

On or about October 27, 2018, in the

'Western

District of Pennsylvania, the defendant,

ROBERT BOWERS, did knowingly use, carry, brandish, and discharge a firearm, to wit, 1) a

Glock .357 handgun, bearing serial number BCUM029;2) a Glock .357 handgun, bearing serial
number YEY449;3) a Glock .357 handgun, bearing serial number RHY244; and4) a Colt AR-l5

rifle, model SP1, bearing serial number SP99907, during and in relation to

a crime

of violence for

which he may be prosecuted in a court of the United States, that is, violations of Title 18, United
States Code, Section 247, as charged at Counts Forty through Fifty-One, and did knowingly and

unlawfully possess

a

firearm in furtherance of said crime of violence,

as

to the civilian and public

safety officer victims listed below.

COUNT

CORRESPONDING CRIME OF
VIOLENCE BY COUNT

52

40

53

4I

54
55
56
57
58
59

42

C.B., A.B., T.M., D.M., and M.S.
A.8., T.M., D.M., and M.S
M.G., A.B., T.M., D.M., and M.S.
A.G., A.B., T.M., D.M., and M.S.
J.M., A.8., T.M., D.M., and M.S.
J.P., A.B., T.M., D.M., and M.S
S.W., A.B., T.M., D.M., and M.S.
B.W., A.8., T.M., D.M., and M.S.
D.D., A.B., T.M., D.M., and M.S.
L.F., A.B., T.M., D.M., and M.S
and M.S
.M.
and M.S.
J.S

J.C.,

43

44
45

46

61

47
48
49

62

50

63

51

60

All in violation of Title 18, United

VICTIMS

States Code, Sections

and924(c)(lXAXiii)

11

92a(c)(1XA)(i),92a@)(1)(AXiD,

 PI]RSUANT TO
NOTICE OF SPECIAL
18, UNITED STATES CODE, SECTIONS 3591 AND 3592

TITLE

The grand jury further finds:

As to Counts One through Eleven and Counts Twenty-Three through Thirty-Three, the
defendant, ROBERT BOWERS,

M.w.,

a.

was 18 years of age or older at the time of the offense;

b.

intentionally killed J.F., R.G., R.M., J.R., C.R., D.R., B.S., S.S., D.S.,

and I.Y. (18 U.S.C. $ 3s91(a)(2)(A));

c.

intentionally inflicted serious bodily injury that resulted in the deaths ofJ.F.,

R.G., R.M., J.R., C.R., D.R., 8.S., S.S., D.S., M.W., and I.Y. (18 U.S.C. $ 3591(a)(2xg));

d.

intentionally participated in an act, contemplating that the life of a person

would be taken and intending that lethal force would be used in connection with a person, other
than one of the participants in the offense, and J.F., R.G., R.M., J.R., C.R., D.R., 8.S., S.S., D.S.,

M.W., and I.Y. died as a direct result of the act (18 U.S.C.
.

e.

$

3591(a)(2XC));

intentionally and specifically engaged in an act of violence, knowing that

the act created a grave risk of death to a person, other than one of the participants in the offense,
such that participation

in the act constituted a reckless disregard for human life, and J.F., R.G.,

R.M., J.R., C.R., D.R., 8.S., S.S., D.S., M.W., and LY. died as a direct result of the act (18 U.S.C.
$

3sel(a)(2Xo));

f.

committed the offenses charged in Counts One tlrough Eleven and Counts

Twenty-Three through Thirty-Three knowingly creating

a

grave

risk of death to one or more

persons in addition to the victims of the offenses, to include responding public safety officers A.B.,
J.C., J.G., J.H., T.M., D.M., A.M., J.P., J.R., M.S., M.S.2 and C.T. (18 U.S.C. $ 3592(cX5));

g.

committed the offenses charged in Counts One through Eleven and Counts

Twenty-Three through Thirty-Three after substantial planning and premeditation to cause the
12

 death of a person (18 U.S.C. $ 3592(cX9));

h.

committed the offenses charged in Counts One, Three, Seven through Ten,

Twenty-Three, Twenty-Fivg, and Twenty-Nine through Thirty-Two, against victims who were
particularly vulnerable due to old age (18 U.S.C. $ 3592(cX1l));

i.

committed the offenses charged in Counts Five, Six, Twenty-Seven, and

Twenty-Eight, against victims who were particularly vulnerable due to infirmity (18 U.S.C.

$

3s92(c)(11)); and

j.

in committing the offenses

charged

in Counts One through Eleven

Counts Twenty-Three through Thirty-Three, intentionally killed and attempted to
one person in a single criminal episode (18 U.S.C. $ 3592(cX16)).

13

and

kill more than

 a

FORFEITURE ALLEGATIONS
The grand jury re-alleges and incorporates by reference the allegations contained in Counts

Twenty-Three through Thirty-Three, Thirty-Eight and Thirty-Nine, and Fifty-Two through SixtyThree of this Superseding Indictment for the purpose of alleging criminal forfeiture pursuant to

Title 18, United States Code, Section 92a@); and Title 28, United States Code, Section zail@).

As part of the commissions of the violations of Title 18, United States Code,

Sections

92a@)Q)@)(i), 92a@)(lXAXii), 92a(c)(1)(Axiii), and 924(t)(l), charged in Counts TwentyThree through Thirty-Three, Thirty-Eight and Thirty-Nine, and Fifty-Two through Sixty-Three

of

this Superseding Indictment, the following firearms, ammunition, and other property, which were
involved and used in the knowing commission of those offenses, are subject to forfeiture pursuant
to Title 18, United States Code, Section 92a@); and Title 28, United States Code, Section 246t(c):

a.

A

Glock .357 handgun bearing serial number BCUM029 and any

ammunition contained therein;

b.

A Glock.357 handgun bearing serial numberYEY4{g and any ammunition

contained therein;

c.

A Glock .357 handgun bearing serial number RHY244 and any ammunition

contained therein;

d.

A Colt AR-15 rifle model SPl bearing serial number

SP99907 and any

ammunition contained therein;

e.

A

shotgun recovered from the scene of the incident and any recovered

ammunition contained therein;

and

\

t4

 t

f.

Any other property, to include ammunition, which was involved and used

in the knowing commission of the offenses specified above.

A True Bill,

FOREPERSON

SCOTT W, BRADY
United States Attomey
PA ID No. 88352

ERIC S. DREIBAND
Assistant Attorney General
Civil Rights Division

i5