CLERKS OFFICE U,S, DIST, COURT

AT CHAFLOTTESVILE, VA
FIL,ED

JUN 2 7 2018
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF \'IRCI}iIA J DL c
B
CHARLOTTESVILLE DIVISION K

UNITED STATES OF AMERICA )

)
) Criminal Number: 3'. tX O€An I
)
JAMES ALEX FIELDS JR. )
) In Violation of:
)
) 18 u.s.c. s 24s(b)(2)(B)
) 18 U.S.C. $ 249(a)(1)
) 18 U.S.C. S 3591
) 18 U.S.C. $ 3s92
)
)

INDICTMENT
The Grand Jury charges:

1. Defendant JAMES ALEX FIELDS JR. is a white male who, on August 12,2017,

was twenty years old.

2. Prior to August 12, 2017, Defendant JAMES ALEX FIELDS JR. obtained

multiple social media accounts, which he used to express his beliefs regarding race, national

origin, religion and other topics. On these accounts, FIELDS expressed and promoted his belief

that white people are superior to other races and peoples; expressed support of the social and

racial policies of Adolf Hitler and Nazi-era Germany, including the Holocaust; and espoused

violence against African Americans, Jewish people and members of other racial; ethnic and

religious groups he perceived to be non-white. FIELDS also expressed these views directly in

interactions with individuals known to him.

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 3. In or around the spring and summer of2017, an event referred to as the "Unite the

Right" rally was organized and scheduled to occur on August 12, 2017 , at Emancipation Park in

Charlottesville, Virginia, which is within the Westem District of Virginia. This rally was

widely promoted on social media and intemet sites associated with white supremacist individuals

and groups, and was scheduled to feature a lineup of well-known white supremacist speakers.

4. On or before August 8, 2017, Defendant JAMES ALEX FIELDS JR. decided to

attend the Unite the Right rally in Charlottesville, Virginia.

5. On August I 1, 2017 , as Defendant JAMES ALEX FIELDS JR. prepared to leave

his home in Maumee, Ohio, to travel to Charlottesville, Virginia, a family member sent him a

text message urging him to be careful. FIELDS replied to the text message that "We're not the

ones who need to be careful." To the message, FIELDS attached an image of Adolf Hitler.

FIELDS departed for Charlottesville, Virginia, shortly thereafter.

6. On or about the aftemoon of August 11,2017 , Defendant JAMES ALEX FIELDS

JR. departed Maumee, Ohio, driving his gray Dodge Challenger bearing Ohio license plate

GVF-1111, and arrived in Charlottesville, Virginia, in the early moming of August 12,2017.

7. On the moming of August 12, 2017, Defendart JAMES ALEX FIELDS JR.

arrived in and around the immediate vicinity of Emancipation Park in Charlottesville, Virginia,

to attend the Unite the Right rally. Multiple groups and individuals espousing white

supremacist and other anti-Semitic and racist views also attended the rally. That morning, these

rally participants, including FIELDS, engaged in chants promoting or expressing white

supremacist and other racist and anti-Semitic views.

8. On August 12, 2017, shortly before the scheduled start of the Unite the fught

rally, law enforcement declared an "unlawful assembly" and required rally participants, including

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Defendant JAMES ALEX FIELDS JR., to disperse. FIELDS later retumed to his vehicle and

began to drive on the streets of Charlottesville, Virginia.

9. On August 12,2017, Defendant JAMES ALEX FIELDS JR. drove his car onto

Fourth Street, a narrow, downhill, one-way street in downtown Charlottesville. At or around

that same time, a racially and ethnically diverse crowd of individuals had gathered at the bottom

of the hill, at the intersection of Fourth and East Water ("Water") Streets. Many of the

individuals in the crowd were chanting and carrying signs promoting equality and protesting

against racial and other forms of discrimination. FIELDS slowly proceeded in his vehicle

toward the crowd and stopped and observed the crowd while idling in his vehicle. With no

vehicle behind him, FIELDS then slowly reversed his vehicle back toward the top of the hill,

near the intersection of Fourth and East Market ("Market") Streets.

10. At or around that same time, the members of the crowd began to walk up Fourth

Street toward Market Sheet, populating the streets and sidewalks between the buildings on

Fourth Street.

11. At or near the top of the hill and the intersection of Fourth and Market Streets,

Defendant JAMES ALEX FIELDS JR. stopped his vehicle. FIELDS rapidly accelerated,

through a stop sign and across a raised pedestrian mall, and drove directly into the crowd.

FIELDS's vehicle stopped only when it struck another vehicle near the intersection ofFourth and

Water Streets. FIELDS then rapidly reversed his car and fled the scene. As FIELDS drove

into and through the crowd, FIELDS struck numerous individuals, killing Heather Heyer and

injuring many others.

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 COUNT ONE
(Hate Crime Act Resulting in Death)
l8 u.s.c. $ 249

12. The allegations set forth in paragraphs I through 11 are repeated and realleged as

if set forth fully herein.

13. On or about August 12, 2077, in Charlottesville, Virginia, within the Westem

District of Virginia, Defendant JAMES ALEX FIELDS JR. willfully caused bodily injury to

Heather Heyer, because of the actual and perceived race, color, religion, and national origin of

individuals in a crowd gathered at and near the intersection of Fourth and Water Streets in

Charlottesville, Virginia, resulting in Heather Heyer's death.

14. A11 in violation of Title 18, United States Code, Section 2a9@)(1).

CO UN'IS TWO THROUGH TWENTY.NINE

(Hate Crime Act lnvolving Attempt to Kill)
18 U.S.C. $ 249

15. The allegations set forth in paragraphs I through I I are repeated and realleged as

if set lorth fully herein.

16. On or about August 12, 2017 , in Charlottesville, Virginia, within the Westem

District of Virginia, Defendant JAMES ALEX FIELDS JR. willfully caused bodily injury to the

below-listed victims, and attempted to cause bodily injury to the below-listed victims through the

use of a dangerous weapon, to wit, a motor vehicle, because of the actual and perceived race,

color, religion, and national origin of individuals in a crowd gathered at and near the intersection

of Fourth and Water Streets in Charlottesville, Virginia:

COUNT T1VO M.B.

COUNT THREE \4.M,

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 COUNT FOUR C.C.

COUNT FIVE T.B

COU\T SIX w.B

COUNT SEVEN N.L.

COTINT EIGHT E.B.

COUN'TNINE A.M

COUNT TEN N.M

COUNT ELEVEN C.A.

COLINT'TWELVE N,R.

COUNT THIRTEEN M.A.N

COU\T FOURTEEN S.S,

COUNT FIFTEEN K.A.

COUNT SIXTEEN C.M.

COUNT SE\'ENTEEN M,R.

COUNTEIGHTEEN A.H

COUNT NII'{ETEEN K-T.

COUNT TWENTY S.L

COUN'I'TWEN'I'Y-ONE C.Y.

COTINT T\}'T-NI'Y-TWO L.Q.

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 COUNT 'TWENTY-THREE T.W

COUNT TWENTY-FOUR M.W

COUNT TWENTY-FIVE B.H

COUNT TWENTY-SIX L.S.

COUNT TWENTY-SEVEN M.J.

COUNT TWENTY-EIGHT A.J.

COUNT TWENTY-NIN T] A.R.

Each offense included an attempt to kill.

17. All in violation ofTitle 18, United States Code, Section 249(a)(1).

COUNT THIRTY
(Bias-Motivated Interference with
Federally Protected Activity Resulting in Death)
18 U.S.C. $ 24s

18. The allegations set forth in paragraphs 1 tkough 1l are repeated and realleged as

if set forth fully herein.

19. On or about August 12, 2011, in Charlottesville, Virginia, within the Westem

District of Virginia, Defendant JAMES ALEX FIELDS JR. by force and tkeat of force, willfully

injured, intimidated, and interfered with, and attempted to injure, intimidate, and interfere with,

individuals in a crowd gathered at and near the intersection of Fourth and Water Streets in

charlottesville, virginia, because of their race, color, religion, and national origin, and because

they were and had been participating in and enjolng a benefit, service, privilege, program,

facility, and activity provided and administered by a state or subdivision thereof, to wit, the

public streets and sidewalks of Charlottesville, Virginia, resulting in the death ofHeather Heyer.

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 20. All in violation of Title 18, United States Code, Section 245(bX2XB)

NOTICE OF SPECIAL FINDINGS PU RSUANT TO

TITLE 18. UNITED STATES CO DE. SECTIONS 3591 AND 3592

The Grand Jury further finds:

21. The allegations set forth in paragraphs 1 through 11 are repeated and realleged as

if set forth fully herein.

22 As to Count Thirty, Defendant JAMES ALEX FIELDS JR.:

(a) was l8 years ofage or older at the time ofthe offense;

(b) intentionally killed Heather Heyer (18 U.S.C. $ 3591(a)(2)(A));

(") intentionally inflicted serious bodily injury that resulted in the death of

Heather Heyer (18 U.S.C. $ 3591(a)(2)(B));

(d) intentionally participated in an act, contemplating that the life ofa 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

Heather Heyer died as a direct result of such act (18 U.S.C. $

35e l(a)(2)(c));

(e) 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 Heather Heyer died as a result of the

act (18 U.S.C. $ 359t(aX2XD));

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 (0 In committing the olfense charged in Count Thirty, knowingly created a

grave risk of death to one or more persons in addition to Heather Heyer

(18 u.s.c. $ 3se2(cXs));

(g) In committing the offense charged in Count Thirty, intentionally killed and

attempted to kill more than one person in a single criminal episode (18

U.S.c. $ 3se2(c)(16)).

A TRUE BILL thisfl day of 201 8.

/s/FO SON
FOREPERSON

THOMAS T. C
IJNITED STATES ATTORNEY

JOHN M. GORE
ACTING ASSISTANT ATTORNEY GENERAL
CIVIL RIGHTS DIVISION