Robert Bowers charged in connection with shooting at Tree of Life synagogue

Bowers, 46, of Baldwin, Pa., was charged with federal hate crimes in connection with the shooting deaths of 11 people at Tree of Life synagogue in Pittsburgh’s Squirrel Hill neighborhood.

Case Document 1 Filed 10/31/18 Page 1 of 12

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF

UNITED STATES OF AMERICA
Criminal No. I 8 7 7-
V.
(18 U.S.C. 247(a)(2), 247(d)(1),
ROBERT BOWERS 247(d)(3),
and
924mm? .-
I
OCT 3 2018
. . CLERK us. DISTRICT COURT
Th6 grand Jury Charges- WEST. DIST. OF

1. At all times relevant to the Indictment, the defendant, ROBERT BOWERS, was a
resident of Allegheny County in the Western District of

2. On the morning of October 27, 2018, members of the Tree of Life, Dor Hadash,
and New Light Jewish congregations gathered to engage in religious worship at the Tree of Life
Synagogue, located at 5898 Wilkins Avenue, Pittsburgh,

3. On the morning of October 27, 2018, the defendant, ROBERT BOWERS, drove to
the Tree of Life Synagogue and entered the building carrying multiple ?rearms. When the
defendant, ROBERT BOWERS, entered the Tree of Life Synagogue, members of the Tree of Life,
Dor Hadash, and New Light congregations were already present within the building.

4. While inside the Tree of Life Synagogue, the defendant, ROBERT BOWERS,
opened ?re, killing and injuring members of the Tree of Life, Dor Hadash, and New Light
congregations, as well as injuring multiple responding public safety of?cers.

5. While inside the Tree of Life Synagogue, the defendant, ROBERT BOWERS made
statements indicating his desire to ?kill Jews.?

6. Paragraphs 1 through 5 of this Indictment are hereby reincorporated as to all Counts

charged below.

Case Document 1 Filed 10/31/18 Page 2 of 12

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 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
J.F.
R.G.
R.M.
C.R.
D.R.
J.R.
B.S.
D.S.
8.8.

M.W.
1 LY.

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 247(a)(2) and 247(d)(1).

Case Document 1 Filed 10/31/18 Page 3 of 12

COUNTS TWELVE THROUGH TWENTY-TWO
(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 the defendant,
ROBERT BOWERS, knowingly used, carried, brandished, and discharged a ?rearm, to wit, 1) a
Glock .357 handgun, bearing serial number 2) a Glock .357 handgun, bearing serial
number 3) a Glock .357 handgun, bearing serial number and 4) a Colt AR-15
ri?e, 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 One through Eleven of this Indictment, and did
knowingly and unlawfully possess a ?rearm in furtherance of said crime of Violence, as to each
Victim set forth below, and caused the death of each Victim listed below through the use of a ?rearm
in such a manner as to constitute murder as de?ned in 18 U.S.C. 1111(a), in that the defendant,

ROBERT BOWERS, with malice aforethought, did unlawfully kill each Victim with a ?rearm.

COUNT VICTIM
12 J.M.W.
22 LY.

All in Violation of Title 18, United States Code, Sections 924(c)(l

and 924mm).

Case Document 1 Filed 10/31/18 Page 4 of 12

COUNTS TWENTY-THREE THROUGH TWENTY-FOUR
(Obstruction of Free Exercise of Religious Beliefs Involving an
Attempt to Kill 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 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
23 D.L.
24 AW.

The acts of the defendant, ROBERT BOWERS, included an attempt to kill each of the victims
named in Counts Twenty?Three and Twenty-Four; and resulted in bodily injury to each of the
victims named in Counts Twenty?Three and Twenty-Four; 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 2) a Glock .357 handgun, bearing serial number 3) a Glock
.357 handgun, bearing serial number and 4) a Colt AR-15 ri?e, model SP1, bearing
serial number and the offense was in and affected interstate commerce.

All in violation of Title 18, United States Code, Sections 247(a)(2), 247(d)(1), and

247(d)(3).

Case Document 1 Filed 10/31/18 Page 5 of 12

COUNTS TWENTY-FIVE THROUGH TWENTY-SIX
(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 the defendant,
ROBERT BOWERS, knowingly used, carried, brandished, and discharged a ?rearm, to wit, 1) a
Glock .357 handgun, bearing serial number 2) a Glock .357 handgun, bearing serial
number 3) a Glock .357 handgun, bearing serial number and 4) a Colt AR-15
ri?e, 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 Twenty-Three through Twenty?Four, and did
knowingly and unlawfully possess a ?rearm in furtherance of said crime of Violence, as to each

victim as set forth below.

COUNT VICTIM
25 BL.
26 A.W.

Allin Violation of Title 18, United States Code, Sections

and

Case Document 1 Filed 10/31/18 Page 6 of 12

COUNT TWENTY-SEVEN THROUGH THIRTY-FOUR
(Obstruction of Free Exercise of Religious Beliefs Involving an Attempt to Kill and
Use of a Dangerous Weapon, and Resulting in Bodily Injury to a Public Safety Of?cer)
On or about October 27, 2018, in the Western District of 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
27 GB.
28 J.C.
29 A.G.
30 MG.
31 J.M.
32 JP.

33 B.W.
34 S.W.

The acts of the defendant, ROBERT BOWERS, included an attempt to kill each of the Victims
named in Counts TwentyuSeven through Thirty?Four; included the use, attempted use, and
threatened use of a dangerous weapon, to wit, 1) a Glock .357 handgun, bearing serial number
2) a Glock .357 handgun, bearing serial number 3) a Glock .357 handgun,
bearing serial number and 4) a Colt AR-15 ri?e, model SP1, bearing serial number
and resulted in bodily injury to A.B., D.M., T.M., and M.S., public safety of?cers who
were then performing duties as a direct and proximate result of the defendant?s conduct as charged
in Counts Twenty-Seven through Thirty-Four; and offense was in and affected interstate
commerce.

All in Violation of Title 18, United States Code, Sections 247(a)(2), 247(d)(1), and

247(d)(3).

Case Document 1 Filed 10/31/18 Page 7 of 12

COUNT
(Obstruction of Free Exercise of Religious Beliefs Involving
Use of a Dangerous Weapon and Resulting in Bodily Injury to a Public Safety Of?cer)

On or about October 27, 2018, in the Western District of the defendant,
ROBERT BOWERS, intentionally obstructed, by force and threat of force, .S., in the enjoyment
of his free exercise of religious beliefs, and attempted to do so. 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 number 2) a Glock .357 handgun,
bearing serial number 3) a Glock .357 handgun, bearing serial number and 4)
a Colt ri?e, model SP1, bearing serial number and resulted in bodily injury to
A.B., D.M., T.M., and M.S., public safety of?cers who were then performing duties as a direct
and proximate result of the defendant?s conduct as charged in Count Thirty Five; and the offense

was in and affected interstate commerce.

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

Case Document 1 Filed 10/31/18 Page 8 of 12

COUNTS THIRTY-SIX THROUGH FORTY-F OUR
(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 the defendant,
ROBERT BOWERS, knowingly used, carried, brandished, and discharged a ?rearm, to wit, 1) a
Glock .357 handgun, bearing serial number 2) a Glock .357 handgun, bearing serial
number 3) a Glock .357 handgun, bearing serial number and 4) a Colt
ri?e, 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 Twenty-Seven through Thirty-Five, and did
knowingly and unlawfully possess a ?rearm in furtherance of said crime of violence, as to each

victim as set forth below.

COUNT VICTIM
36 CE.
37 J.C.
38 AG.
39 MG.
40 J.M.
41 JP.

42 J.S.
43 B.W.
44 SW.

All in violation of Title 18, United States Code, Sections

Case Document 1 Filed 10/31/18 Page 9 of 12

NOTICE OF SPECIAL FINDINGS PURSUANT TO
TITLE 18, UNITED STATES CODE. SECTIONS 3591 AND 359;

The grand jury further ?nds:
As to Counts One through Twenty-Two, the defendant, ROBERT BOWERS,

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

b. intentionally killed J.F., R.G., R.M., C.R., D.R., J.R., B.S., D.S.,
M.W., and LY. (18 U.S.C.

c. intentionally in?icted serious bodily injury that resulted in the deaths of .F.,
R.G., R.M., C.R., D.R., J.R., B.S., D.S., S.S., M.W., and I.Y. (18 U.S.C.

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., C.R., D.R., J.R., B.S., D.S., S.S.,
M.W., and I.Y. died as a direct result ofthe act (18 U.S.C.

e. intentionally and speci?cally 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 .F., R.G.,
R.M., C.R., D.R., J.R., B.S., D.S., S.S., M.W., and LY. died as a direct result ofthe act (18 U.S.C.

f. committed the offenses charged in Counts One through Twenty?Two
knowingly creating a grave risk of death to one or more persons in addition to the Victims of the
offenses (18 U.S.C. 3592(c)(5));

g. committed the offenses charged in Counts One through Twenty?Two after

substantial planning and premeditation to cause the death of a person (18 U.S.C. 3592(c)(9));

Case Document 1 Filed 10/31/18 Page 10 of 12

h. committed the offenses charged in Counts One, Three, Seven through Ten,
Twelve, Fourteen, and Eighteen through Twenty?One, against victims who were particularly
vulnerable due to old age (18 U.S.C. 3592(c)(11));

i. committed the offenses charged in Counts Four, Five, Fifteen, and Sixteen,
against victims who were particularly vulnerable due to in?rmity (18 U.S.C. 3592(c)(11)); and

j. in committing the offenses charged in Counts One through Twenty?Two,
intentionally killed and attempted to kill more than one person in a single criminal episode (18

U.S.C. 3592(c)(16)).

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Case Document 1 Filed 10/31/18 Page 11 of 12

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

Twelve through Twenty-Two, Twenty-Five through Twenty?Six, and Thirty-Six through Forty?
Four of this Indictment for the purpose of alleging criminal forfeiture pursuant to Title 18, United
States Code, Section 924(d); and Title 28, United States Code, Section 2461(0). As part of the
commissions of the violations of Title 18, United States Code, Sections
and 9240)(l), charged in Counts Twelve through
Twenty-Two, Twenty-Five through Twenty-Six, and Thirty?Six through orty?Four of this
Indictment, the following ?rearms and ammunition, which were involved and used in the knowing
commissions of those offenses, are subject to forfeiture pursuant to Title 18, United States Code,
Section 924(d); and Title 28, United States Code, Section 2461(0):

a. A Glock .357 handgun bearing serial number BCUM029 and any
ammunition contained therein;

b. A Glock .357 handgun bearing serial number YEY449 and any ammunition
contained therein;

c. A Glock .357 handgun bearing serial number RHY244 and any ammunition
contained therein;

(1. A Colt ri?e model SP1 bearing serial number SP99907 and any
ammunition contained therein;

e. A shotgun recovered from the scene of the incident and any ammunition

contained therein; and

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Case Document 1 Filed 10/31/18 Page 12 of 12

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

in the knowing commission of the offenses speci?ed above.

A Tmi/l?ill,


SCOTT w. BRADY L)
United States Attorney
PA ID No. 88352

JOHN M. GORE
Acting Assistant Attorney General
Civil Rights Division

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