# Domestic Terrorism: An Overview

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/crs%3AR44921

## Record

- **Collection:** Congressional research report
- **Document type:** CRS Report
- **Published:** August 21, 2017
- **Citation:** R44921

## Text

Domestic Terrorism: An Overview
,name redacted,
Specialist in Organized Crime and Terrorism
August 21, 2017

Congressional Research Service
7-....
www.crs.gov
R44921

Domestic Terrorism: An Overview

Summary
The emphasis of counterterrorism policy in the United States since Al Qaeda’s attacks of
September 11, 2001 (9/11) has been on jihadist terrorism. However, in the last decade, domestic
terrorists—people who commit crimes within the homeland and draw inspiration from U.S.-based
extremist ideologies and movements—have killed American citizens and damaged property across
the country. Not all of these criminals have been prosecuted under federal terrorism statutes,
which does not imply that domestic terrorists are taken any less seriously than other terrorists.
The Department of Justice (DOJ) and the Federal Bureau of Investigation (FBI) do not officially
designate domestic terrorist organizations, but they have openly delineated domestic terrorist
“threats.” These include individuals who commit crimes in the name of ideologies supporting
animal rights, environmental rights, anarchism, white supremacy, anti-government ideals, black
separatism, and beliefs about abortion.
The boundary between constitutionally protected legitimate protest and domestic terrorist activity
has received public attention. This boundary is highlighted by a number of criminal cases
involving supporters of animal rights—one area in which specific legislation related to domestic
terrorism has been crafted. The Animal Enterprise Terrorism Act (P.L. 109-374) expands the
federal government’s legal authority to combat animal rights extremists who engage in criminal
activity. Signed into law in November 2006, it amended the Animal Enterprise Protection Act of
1992 (P.L. 102-346).
This report is intended as a primer on the issue, and four discussion topics in it may help explain
domestic terrorism’s relevance for policymakers:







Level of Activity. Domestic terrorists have been responsible for orchestrating
numerous incidents since 9/11.
Use of Nontraditional Tactics. A large number of domestic terrorists do not
necessarily use tactics such as suicide bombings or airplane hijackings. They
have been known to engage in activities such as vandalism, trespassing, and tax
fraud, for example.
Exploitation of the Internet. Domestic terrorists—much like their jihadist
analogues—are often Internet and social-media savvy and use such platforms to
share ideas and as resources for their operations.
Decentralized Nature of the Threat. Many domestic terrorists rely on the
concept of leaderless resistance. This involves two levels of activity. On an
operational level, militant, underground, ideologically motivated cells or
individuals engage in illegal activity without any participation in or direction
from an organization that maintains traditional leadership positions and
membership rosters. On another level, the above-ground public face (the
“political wing”) of a domestic terrorist movement may focus on propaganda and
the dissemination of ideology—engaging in protected speech.

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Domestic Terrorism: An Overview

Contents
Introduction ..................................................................................................................................... 1
Domestic Terrorism Defined ........................................................................................................... 2
What Is Domestic Terrorism?.................................................................................................... 3
Toward a Narrower Definition ............................................................................................ 4
Ambiguity Regarding “U.S.-Based Extremist Ideologies” ................................................. 4
Factors Complicating the Descriptions of the Domestic Terrorism Threat ............................... 5
Counting Terrorism Cases ................................................................................................... 5
Sifting Domestic Terrorism from Other Illegal Activity ..................................................... 6
Extremism vs. Terrorism ..................................................................................................... 8
The Lack of an Official Public List .................................................................................... 9
Toward a Practical Definition: Threats Not Groups ................................................................ 10
Animal Rights Extremists and Environmental Extremists.................................................11
Anarchist Extremists ......................................................................................................... 13
White Supremacist Extremists .......................................................................................... 16
Anti-Government Extremists ............................................................................................ 23
Black Separatist Extremists .............................................................................................. 32
Abortion Extremists .......................................................................................................... 33
Protected Activities vs. Terrorism—Divergent Perceptions of the ALF ................................. 35
A Serious Domestic Concern or “Green Scare?” .............................................................. 35
Assessing Domestic Terrorism’s Significance............................................................................... 39
Counting Incidents .................................................................................................................. 40
“Nonviolent” Strategies .......................................................................................................... 41
Direct Action ..................................................................................................................... 41
The ALF: “Live Liberations” and “Economic Sabotage” ................................................. 42
The ELF: “Monkeywrenching” ........................................................................................ 42
“Paper Terrorism”: Liens, Frivolous Lawsuits, and Tax Schemes .................................... 46
The Internet and Domestic Terrorists ...................................................................................... 48
A Decentralized Threat............................................................................................................ 50
Leaderless Resistance ....................................................................................................... 50
Lone Wolves ..................................................................................................................... 53
Scoping the Threat Remains Difficult for Policymakers ............................................................... 57
Terminology ............................................................................................................................ 57
Designating Domestic Terrorist Groups .................................................................................. 57
A Public Accounting of Plots and Incidents ............................................................................ 58
Better Sense of Scope May Assist Policymakers .................................................................... 59

Figures
Figure 1. ALF and ELF Guidelines ............................................................................................... 45

Contacts
Author Contact Information .......................................................................................................... 59

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Introduction
Since the terrorist attacks of September 11, 2001 (9/11), domestic terrorists—people who commit
crimes within the homeland and draw inspiration from U.S.-based extremist ideologies and
movements1—have not received as much attention from federal law enforcement as their violent
jihadist counterparts. This was not necessarily always the case. The Federal Bureau of
Investigation (FBI) reported in 1999 that “[d]uring the past 30 years, the vast majority—but not
all—of the deadly terrorist attacks occurring in the United States have been perpetrated by
domestic extremists.”2
The U.S. government reacted to 9/11 by greatly enhancing its counterterrorism efforts. This report
discusses how domestic terrorists broadly fit into the counterterrorism landscape, a terrain that
since 9/11 has been largely shaped in response to terrorists inspired by foreign ideologies. This
report focuses especially on how domestic terrorism is conceptualized by the federal government
and issues involved in assessing this threat’s significance. Today (perhaps in part because of the
government’s focus on international terrorist ideologies), it is difficult to evaluate the scope of
domestic terrorist activity. For example, federal agencies employ varying terminology and
definitions to describe it.
Possibly contributing to domestic terrorism’s secondary status as a threat at the federal level, a
large number of those labeled as domestic terrorists do not necessarily use traditional terrorist
tactics such as bombings or airplane hijackings. Additionally, many domestic terrorists do not
intend to physically harm people but rather rely on alternative tactics such as theft, trespassing,
destruction of property, and burdening U.S. courts with retaliatory legal filings.
While plots and attacks by foreign-inspired homegrown violent jihadists have earned more media
attention, domestic terrorists have been busy as well. It is worth noting that in terms of casualties
on U.S. soil, an act of domestic terrorism is second only to the events of 9/11. Timothy McVeigh’s
bombing of the Alfred P. Murrah Federal Building in Oklahoma City on April 19, 1995, claimed
168 lives and injured more than 500 others. Some estimates suggest that domestic terrorists are
responsible for carrying out dozens of incidents since 9/11.3 Much like their jihadist counterparts,
domestic terrorists are often Internet savvy and use the medium as a resource for their operations.
Terrorists are typically driven by particular ideologies. In this respect, domestic terrorists are a
widely divergent lot, drawing from a broad array of philosophies and worldviews. These
individuals can be motivated to commit crimes in the name of ideas such as animal rights, white
supremacy, and abortion, for example. However, the expression of these worldviews (minus the
commission of crimes) involves constitutionally protected activity.
1

This conceptualization of the term “domestic terrorism” is derived from a number of U.S. government sources
detailed in this report. This report will not focus on homegrown violent jihadists. However, when referring to such
actors, for this report, “homegrown” describes terrorist activity or plots perpetrated within the United States or abroad
by American citizens, permanent legal residents, or visitors radicalized largely within the United States. “Jihadist”
describes radicalized Muslims using Islam as an ideological and/or religious justification for belief in the establishment
of a global caliphate—a jurisdiction governed by a Muslim civil and religious leader known as a caliph—via violent
means. Jihadists largely adhere to a variant of Salafi Islam—the fundamentalist belief that society should be governed
by Islamic law based on the Quran and follow the model of the immediate followers and companions of the Prophet
Muhammad.
2
Federal Bureau of Investigation, Terrorism in the United States: 30 Years of Terrorism—A Special Retrospective
Edition, (2000) p. 16.
3
New America Foundation, Terrorism in America After 9/11: Part IV, What is the Threat to the United States Today?
https://www.newamerica.org/in-depth/terrorism-in-america/what-threat-united-states-today/.

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Aware of the lines between constitutionally protected speech and criminality, domestic terrorists
often rope themselves off from ideological (above-ground) elements that openly and often legally
espouse similar beliefs. In essence, the practitioners who commit violent acts are distinct from the
propagandists who theorize and craft worldviews that could be interpreted to support these acts.
Thus, in decentralized fashion, terrorist lone actors (lone wolves) or isolated small groups (cells)
generally operate autonomously and in secret, all the while drawing ideological sustenance—not
direction—from propagandists operating in the free market of ideas.
Domestic terrorists may not be the top federal counterterrorism priority, but they feature
prominently among the concerns of some law enforcement officers. For example, in 2011, Los
Angeles Deputy Police Chief Michael P. Downing included “black separatists, white
supremacist/sovereign citizen extremists, and animal rights terrorists” among his chief
counterterrorism concerns.4 A 2014 national survey of state and local law enforcement officers
found that sovereign citizens were “the top concern” among terrorist threats.5
The violence related to protests in Charlottesville, VA, on August 12, 2017, also has raised the
issue of domestic terrorism, particularly related to public discussions regarding a widely reported
incident involving James Alex Fields, who according to witnesses drove his car into a group of
people protesting a rally featuring white supremacists in Charlottesville on August 12.6 Fields
allegedly killed one person and injured 19 others in the incident. The Department of Justice
(DOJ) has opened a civil rights investigation into the incident, presumably pursuing possible hate
crime charges.7 Additionally, Attorney General Jeff Sessions has publicly stated that terrorism
investigators are involved in investigating the incident, ostensibly exploring the possibility of
characterizing it as an act of domestic terrorism rather than a hate crime.8
This report provides background regarding domestic terrorists—detailing what constitutes the
domestic terrorism threat as suggested by publicly available U.S. government sources. 9 It
illustrates some of the key factors involved in assessing this threat. This report does not discuss in
detail either violent jihadist-inspired terrorism or the federal government’s role in
counterterrorism investigations.

Domestic Terrorism Defined
Two basic questions are key to understanding domestic terrorism. First, what exactly constitutes
“domestic terrorism?” Answering this question is more complicated than it may appear. Some
4

Bill Gertz, “L.A. Police Use Intel Networks against Terror,” Washington Times, April 11, 2011. See also Joshua D.
Freilich, Steven M. Chermak & Joseph Simone Jr. “Surveying American State Police Agencies About Terrorism
Threats, Terrorism Sources, and Terrorism Definitions,” Terrorism and Political Violence, vol. 21, no. 3 (2009) pp.
450-475. Freilich, Chermak, and Simone found that domestic terrorist groups featured prominently among the concerns
of U.S. state police officials.
5
Jessica Rivinius, “Sovereign Citizen Movement Perceived as Top Terrorist Threat,” National Consortium for the
Study of Terrorism and Responses to Terrorism, July 30, 2014. For the report, see Carter, David, et al., “Understanding
Law Enforcement Intelligence Processes,” National Consortium for the Study of Terrorism and Responses to
Terrorism, 2014.
6
T. Rees Shapiro et. al., “Alleged Driver of Car that Plowed into Charlottesville Crowd Was a Nazi Sympathizer,
Former Teacher Says,” Washington Post, August 13, 2017.
7
Department of Justice, “Joint Statement from United States Attorney’s Office for the Western District of Virginia,
Federal Bureau of Investigation and the Civil Rights Division,” press release, August, 13, 2017.
8
Michael Edison Hayden, “Sessions Defends Trump’s Comments on Charlottesville, Says Car Ramming Fits
Definition of Domestic Terror,” ABC News, August 14, 2017.
9
This report does not presume the guilt of indicted individuals in pending criminal cases.

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consider all terrorist plots occurring within the homeland as acts of domestic terrorism. According
to this perspective, a bombing plot involving U.S. citizens motivated by a foreign terrorist group
such as Al Qaeda or the Islamic State constitutes domestic terrorism. While this conceptualization
may be true at some level, a practical definition of domestic terrorism distilled from federal
sources is much narrower. It suggests that domestic terrorists are Americans who commit
ideologically driven crimes in the United States but lack foreign direction or influence—whether
tactical or philosophical. This conceptualization excludes homegrown individuals directed or
motivated by groups such as Al Qaeda or the Islamic State. Second, what particular groups are
considered domestic terrorist organizations? The U.S. government does not provide a precise,
comprehensive, and public answer to this question. Rather, in broad terms, DOJ has identified a
number of general threats that embody this issue. The ideological concepts that underpin such
threats may inspire criminal activity, such as hate crimes, that do not rise to the level of terrorism.
This further complicates defining “domestic terrorism.”

What Is Domestic Terrorism?
In the most general statutory terms, a domestic terrorist engages in terrorist activity that occurs in
the homeland. The Federal Bureau of Investigation (FBI, the Bureau) has lead responsibility for
terrorism investigations at the federal level.10
The FBI generally relies on two fundamental sources to define domestic terrorism. First, the Code
of Federal Regulations characterizes “terrorism” as including “the unlawful use of force and
violence against persons or property to intimidate or coerce a government, the civilian population,
or any segment thereof, in furtherance of political or social objectives.”11 Second, 18 U.S.C.
Section 2331(5) more narrowly defines “domestic terrorism” and differentiates it from
international terrorism and other criminal activity.12 This definition comes from Section 802 of
the USA PATRIOT Act (P.L. 107-56). According to 18 U.S.C. Section 2331(5), domestic
terrorism occurs primarily within U.S. territorial jurisdiction, and involves
(A) ... acts dangerous to human life that are a violation of the criminal laws of the United
States or of any State;
(B) appear to be intended—
(i) to intimidate or coerce a civilian population;
(ii) to influence the policy of a government by intimidation or coercion; or
(iii) to affect the conduct of a government by mass destruction, assassination, or
kidnapping.... 13

10

28 C.F.R. §0.85.
Ibid.
12
U.S. Congress, Senate Committee on Environment and Public Works, “Responses of John E. Lewis [then Deputy
Assistant Director, Federal Bureau of Investigation] to Additional Questions from Senator Obama,” Eco-Terrorism
Specifically Examining the Earth Liberation Front and the Animal Liberation Front, 109th Cong., 1st sess., May 18,
2005, S. Hrg. 109-947 (Washington: GPO, 2007), p. 41. Hereinafter: Responses of John E. Lewis.
13
18 U.S.C. §2331(5).
11

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Enforcement—Joint Terrorism Task Forces
Aside from the FBI, other federal agencies such as the Bureau of Alcohol Tobacco Firearms and Explosives (ATF) and
the Internal Revenue Service (IRS) play a role in enforcement efforts to counter domestic terrorism. These
agencies—as well as state and local law enforcement representatives—typically cooperate within the framework of
Joint Terrorism Task Forces (JTTFs), multi-agency investigative units led by DOJ and the FBI across the country.14
JTTFs are teams of police officers, federal agents, analysts, linguists, SWAT experts, and other specialists who
investigate terrorism and terrorism-related crimes. Seventy-one of the more than 100 JTTFs operated by DOJ and
the FBI were created since 9/11. About 4,000 federal, state, and local law enforcement officers and agents—more
than four times the pre-9/11 total—work in them. These officers and agents come from more than 500 state and
local agencies and 50 federal agencies.15
The FBI considers JTTFs “the nation’s front line on terrorism.”16 They “investigate acts of terrorism that affect the
U.S., its interests, property and citizens, including those employed by the U.S. and military personnel overseas.”17 As
this suggests, their operations are highly tactical and can involve developing human sources (informants) as well as
gathering intelligence to thwart terrorist plots. JTTFs also offer an important conduit for the sharing of intelligence
developed from FBI-led counterterrorism investigations with outside agencies and state and local law enforcement.18

Toward a Narrower Definition
The definitions cited above are too broad to capture what the FBI specifically investigates as
“domestic terrorism.” Besides the statutory definitions regarding the crime of domestic terrorism,
the FBI has historically emphasized particular qualities inherent to the actors who engage in
domestic terrorism. According to the Bureau, domestic terrorists do not simply operate in the
homeland, but they also lack foreign direction.19 In fact, the Bureau’s practical, shorthand
definition of domestic terrorism is “Americans attacking Americans based on U.S.-based
extremist ideologies.”20 The Department of Homeland Security (DHS) follows this construction.21

Ambiguity Regarding “U.S.-Based Extremist Ideologies”
On the surface, the FBI’s shorthand definition for domestic terrorism appears straightforward.
However, there is inherent ambiguity to it. Namely, some of the “U.S.-based extremist
ideologies” driving what the Bureau views as domestic terrorism have international roots and
active followings abroad. The ideologies supporting eco-extremism and animal rights extremism
(discussed below) readily come to mind, and people have long committed crimes in their names
outside the United States.22 At least in part, their origins lay in the United Kingdom. Nazism—
14

Federal Bureau of Investigation, “Joint Terrorism Task Forces.”
Ibid.
16
Federal Bureau of Investigation, “Protecting America against Terrorist Attack: A Closer Look at Our Joint Terrorism
Task Forces,” May 2009.
17
Brig Barker and Steve Fowler, “The FBI Joint Terrorism Task Force Officer,” The FBI Law Enforcement Bulletin,
vol. 77, no. 11 (November 2008), p. 13.
18
Kevin Johnson, “FBI Issues More Top Secret Clearance for Terrorism Cases,” USA Today, August 12, 2010;
STRATFOR, A Decade of Evolution in U.S. Counterterrorism Operations, Special Report, December 2009.
19
James F. Jarboe, [then Domestic Terrorism Section Chief, Counterterrorism Division] Federal Bureau of
Investigation, Testimony Before the House Resources Committee, Subcommittee on Forests and Forest Health,
February 12, 2002. Hereinafter: Jarboe, Testimony.
20
Federal Bureau of Investigation, “Domestic Terrorism in the Post-9/11 Era,” September 7, 2009. Hereinafter: Federal
Bureau of Investigation, “Domestic Terrorism.”
21
See Department of Homeland Security, “Domestic Terrorism and Homegrown Violent Extremism Lexicon,”
November 10, 2011. Hereinafter: Department of Homeland Security, “Domestic Terrorism and Homegrown.”
22
See Gary A. Ackerman, “Beyond Arson? A Threat Assessment of the Earth Liberation Front,” Terrorism and
(continued...)
15

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with its German origins and foreign believers—is an element within domestic white supremacist
extremism. Anarchism, the philosophy followed by anarchist extremists, also has long-standing
European roots. The racist skinhead movement traces its origins abroad—to the United
Kingdom—as well. These examples illustrate the FBI’s challenge when it emphasizes U.S.-based
ideologies in its framing of domestic terrorism.

Factors Complicating the Descriptions of the Domestic
Terrorism Threat
A few more issues make it hard to grasp the breadth of domestic terrorist activity in the United
States. First, counting the number of terrorist prosecutions or plots in general has been difficult in
the post-9/11 period. Second, there may be some ambiguity in the investigative process regarding
exactly when criminal activity becomes domestic terrorism. Third, the federal government
appears to use the terms “terrorist” and “extremist” interchangeably when referring to domestic
terrorism. It is unclear why this is the case. Finally, and most importantly, which specific groups
are and should be considered domestic terrorist organizations? The U.S. government does not
provide a public answer to this question. Rather, the federal government defines the issue in terms
of “threats,” not groups.

Counting Terrorism Cases
While statutory and practical federal definitions exist for “domestic terrorism,” there is little clear
sense of the scope of the domestic terrorist threat based on publicly available U.S. government
information. Most broadly, it has been said that in much of the post-9/11 period, the federal courts
and DOJ may have applied different parameters when sorting, counting, and categorizing all
types of terrorist prosecutions—let alone domestic terrorism cases.23 A 2009 study (critiqued by
DOJ) found that the U.S. federal district courts, DOJ’s National Security Division, and federal
prosecutors rely on different criteria to determine whether or not specific cases involve terrorism
at all.24
A bit more narrowly, in many instances, individuals considered to be domestic terrorists by
federal law enforcement may be charged under non-terrorism statutes, making it difficult to grasp
from the public record exactly how extensive this threat is. Regarding the prosecution of domestic
terrorism cases, no separate federal crime of “domestic terrorism” exists.25 Also, DOJ has noted
that, “[a]lthough we do have at least one specialized [federal] statute aimed at animal enterprise
terrorism,26 domestic terrorism cases often involve firearms, arson or explosive offenses; crimes
relating to fraud; and threats and hoaxes.”27 In some instances, the crimes committed by people
(...continued)
Political Violence, vol. 15, no. 4 (2003), pp. 155-156. Hereinafter: Ackerman, “Beyond Arson?”
23
Transactional Records Access Clearinghouse (TRAC), Who Is a Terrorist? Government Failure to Define Terrorism
Undermines Enforcement, Puts Civil Liberties at Risk, September 8, 2009, http://trac.syr.edu/tracreports/terrorism/215/.
DOJ issued a press release that broadly challenged these findings and suggested that TRAC may have omitted certain
statistics in its study. TRAC refuted these claims. For the interchange between DOJ and TRAC, see http://trac.syr.edu/
tracreports/terrorism/219/.
24
Ibid.
25
Greg Myre, “Why the Government Can’t Bring Terrorism Charges in Charlottesville,” NPR, August 14, 2017.
26
This likely refers to the Animal Enterprise Protection Act from 1992. In late 2006 shortly after the white paper’s
publication, this act was amended by the Animal Enterprise Terrorism Act.
27
Department of Justice, Counterterrorism White Paper, June 22, 2006, p. 59. Hereinafter: Department of Justice,
(continued...)

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the FBI describes as domestic terrorism suspects do not violate federal law. When this occurs, the
Bureau, “support[s] [its local] partners any way [it] can—sharing intelligence, offering forensic
assistance, conducting behavioral analysis, etc.”28 Thus, individuals considered domestic
terrorists by federal law enforcement may not necessarily be federally charged as terrorists.

Sifting Domestic Terrorism from Other Illegal Activity
It may not be possible for investigators to describe the criminal activity involved early in an
investigation as domestic terrorism. In these instances, investigators can work toward clarifying
the motives of the suspects involved.29 Domestic terrorism cases differ from ordinary criminal
activity in key ways. Most importantly, unlike ordinary criminals—who are often driven by selfcentered motives such as profit and tend to opportunistically seek easy prey—domestic terrorists
are driven by a cause or ideology.30 If the motives involved align with the definition laid out in 18
U.S.C. Section 2331(5), presumably the case becomes a domestic terrorist investigation. In some
instances, ideologically motivated actors can also collaborate with profit-driven individuals to
commit crimes.
To further cloud matters, another category of criminal activity, hate crime, may appear to involve
ideological issues. However, as described by one federal official, a “hate crime” “generally
involve[s] acts of personal malice directed at individuals” and is missing the broader motivations
driving acts of domestic terrorism.31 For investigators, distinguishing between “personal malice”
and ideologically motivated actions may be difficult in specific cases. This suggests that sorting
domestic terrorism from hate crimes depends on the degree of a suspect’s intent. Did the suspect
articulate an ideology belonging to an extremist movement? The grey area between domestic
terrorism and hate crime hints that in some instances, suspects with links to domestic terrorist
movements or ideologies supporting domestic terrorism may be charged with hate crimes. 32 It is
unclear to what extent this influences how the government understands the threat posed by
extremist movements that hold racist beliefs. If some individuals of this ilk commit crimes
against police or judges, for example, is the government more apt to label this activity as
terrorism while individuals sharing these same racist motivations but targeting ordinary citizens
based on race, religion, disability, ethnic origin, or sexual orientation are charged with hate
crimes?

(...continued)
White Paper.
28
See CRS Legal Sidebar WSLG1858, Charlottesville Car Crash Attack: Possibility of Federal Criminal Prosecution,
by (name redacted)
. See also Federal Bureau of Investigation, “Domestic Terrorism.”
29
Responses of John E. Lewis, pp. 41, 42.
30
In some instances such as those involving white-supremacist prison gangs who espouse extremist beliefs, the profit
motive may be paramount in their criminal activity. See Joshua D. Freilich, Steven M. Chermak, and David Caspi,
“Critical Events in the Life Trajectories of Domestic Extremist White Supremacist Groups,” Criminology and Public
Policy, vol. 8, no. 3 (August 2009), p. 508. Hereinafter: Freilich, Chermak, and Caspi, “Critical Events.”
31
Responses of John E. Lewis, p. 41.
32
While this discussion focuses on intent, domestic terrorists can exhibit additional traits that distinguish them from
other offenders. For example, as part of their involvement in ideological movements, domestic terrorists often are
exposed to more tactical training—in weapons, explosives, arson, reconnaissance, paramilitary discipline—than many
more ordinary criminals. See Anti-Defamation League, Guidebook on Extremism for Law Enforcement, (2007), p. 9.
Hereinafter: Anti-Defamation League, Guidebook.

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Two Cases Demonstrating Blurred Lines Between
Hate Crime and Domestic Terrorism
When it comes to characterizing ideologically inspired criminal actors for investigative purposes, the FBI occasionally
confronts suspects who can be viewed either as terrorists or as perpetrators of hate crimes. Precisely
understanding suspect’s motives (among other things) can be useful in categorizing his or her case as either a
domestic terrorism or hate crime investigation.33 However, when it comes to prosecution, one can say that such
considerations are somewhat more limited, namely because no separate federal crime of “domestic terrorism”
exists.34 Federal prosecutors can pursue hate crimes charges or other criminal offenses that fit the crime.35 While
pursing such non-terrorism charges, prosecutors may avoid publicly describing suspects as domestic terrorists.
Dylann Roof
On June 17, 2015, Dylann Roof shot and killed nine African Americans in the Emanuel African Methodist Episcopal
Church in Charleston, SC. Three churchgoers survived. DOJ pursued a case involving federal hate crimes and
firearms charges.36 Roof was sentenced to death by a federal jury.37 According to DOJ, before the shooting incident,
Roof had posted on a website a manuscript and photos “expressing his racist beliefs.” Additionally, DOJ argued that
he “wanted to increase racial tensions across the Nation, and sought retribution for perceived wrongs he believed
African-Americans had committed against white people.”38 Although it seems that Roof’s alleged motives had
ideological underpinnings in white supremacy, then-Attorney General Loretta E. Lynch noted in 2015 that DOJ
pursued federal hate crimes charges because “[w]e think that this is exactly the type of case that the federal hate
crimes statutes were, in fact, conceived to cover.”39
Kevin Harpham
The FBI’s public description of the case of confessed would-be bomber Kevin Harpham is an example of how
difficult it may be to characterize acts as domestic terrorism. Initially, the FBI viewed the case as domestic terrorism.
In 2011, Harpham, motivated by white supremacist ideology, left a bomb—which never detonated—along the route
of a parade in Spokane, WA, honoring Dr. Martin Luther King, Jr. The FBI’s Northwest Joint Terrorism Task Force
led the investigation.40 In prepared public remarks framing the “current state of the terrorism threat” from April
2011, the then-FBI Assistant Director for the Counterterrorism Division noted that Harpham’s case was one of
“several recent domestic terrorism incidents [that] demonstrate the scope of the threat.”41 Harpham eventually
pled guilty to committing a federal hate crime and attempting to use a weapon of mass destruction.42 Thereafter, the
Bureau described the case as the successful prevention of a “horrific hate crime.”43

33

Investigating an individual as a terrorist may confer more resources to an investigation and may offer more
investigative options. Regarding the latter, see American Civil Liberties Union, “How the USA PATRIOT Act
Redefines ‘Domestic Terrorism,’” https://www.aclu.org/other/how-usa-patriot-act-redefines-domestic-terrorism.
34
Greg Myre, “Why the Government Can’t Bring Terrorism Charges in Charlottesville,” NPR, August 14, 2017.
35
For a discussion of federal hate crimes, see Department of Justice, “Hate Crime Laws,” https://www.justice.gov/crt/
hate-crime-laws.
36
Department of Justice, “Attorney General Lynch Statement Following the Federal Grand Jury Indictment Against
Dylann Storm Roof,” press release, July 22, 2015. DOJ also sought the death penalty. Department of Justice, “Attorney
General Loretta E. Lynch Statement on the Case of Dylann Roof,” press release, May 24, 2016.
37
Department of Justice, “Federal Jury Sentences Dylann Storm Roof to Death,” press release, January 10, 2017.
38
United States v. Dylann Storm Roof, indictment, U.S. District Court, District of South Carolina, June 20, 2015.
39
Christina Maza, “Why is Dylann Roof Not Facing Charges of Terrorism?” Christian Science Monitor, July 24, 2015.
40
Department of Justice, “Attempted Bomber Arrested,” press release, March 9, 2011.
41
Mark F. Giuliano, Assistant Director, Counterterrorism Division, Federal Bureau of Investigation, prepared remarks
delivered at the Washington Institute for Near East Policy, Stein Program on Counterterrorism and Intelligence,
Washington, DC, April 14, 2011, http://www.fbi.gov/news/speeches/the-post-9-11-fbi-the-bureaus-response-toevolving-threats.
42
Department of Justice, “Attempted Bomber Pleads Guilty to Federal Hate Crime and Weapons Charge,” press
release, September 7, 2011.
43
Federal Bureau of Investigation, “MLK Parade Bomber,” January 13, 2012; Department of Justice, press release,
“Colville, Wash., Man Indicted for Federal Hate Crime in Attempted Bombing of the MLK Unity March,” press
release, April 21, 2011.

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Extremism vs. Terrorism
Another concept that muddies discussion of domestic terrorism is “extremism.” The latter term is
commonly applied to homegrown actors, whether they be domestic terrorists or adherents of
ideologies forwarded by foreign groups such as Al Qaeda. National security expert Jonathan
Masters has suggested that many law enforcement officials likely view “extremism” as largely
synonymous with “terrorism.”44 Masters has also found that there is a “lack of uniformity in the
way domestic terrorist activities are prosecuted” in the United States.45 Presumably, using the
term “extremist” allows prosecutors, policymakers, and investigators the flexibility to discuss
terrorist-like activity without actually labeling it as “terrorism” and then having to prosecute it as
such. This flexibility is certainly an asset to prosecutors. They can charge subjects of FBI
domestic terrorism investigations under a wider array of statutes without having to convince a
jury that the accused were terrorists. However, for policymakers this flexibility makes it hard to
determine the scope of the domestic terrorist threat. One cannot get a clear sense of scope if some
individuals are charged and publicly described as terrorists, others are discussed as extremists,
and still others enter the public record only as criminals implicated in crimes not necessarily
associated with terrorism, such as trespassing, arson, and tax fraud.

What Is Extremism?
The FBI’s public formulation of “extremism” suggests two components. First, extremism
involves hewing to particular ideologies. Second, it also includes criminal activity to advance
these ideologies.46 Thus, according to this construction, an anarchist believes in a particular
ideology—anarchism. An “anarchist extremist” is an anarchist who adopts criminal tactics.47
One scholar has indicated a similar bifurcation: First, extremism refers to an ideology outside a
society’s key values, and for liberal democracies, such ideologies “support racial or religious
supremacy and/or oppose the core principles of democracy and human rights.” Second,
extremism can refer to the use of tactics that ignore the rights of others to achieve an
ideological goal.48

44

Jonathan Masters, Militant Extremists in the United States, Council on Foreign Relations, Washington, DC, February
7, 2011.
45
Ibid.
46
Federal Bureau of Investigation, “Domestic Terrorism: Anarchist Extremism, A Primer,” December 16, 2010. The
focus of this piece, as the title suggests, is anarchist extremism, not necessarily defining the term “extremism.”
Hereinafter: Federal Bureau of Investigation, “Anarchist Extremism.” This type of formulation—extremism consists of
adherence to ideologies and criminal activity committed in the name of these ideologies—is replicated in the
definitions provided within Department of Homeland Security, “Domestic Terrorism and Homegrown.”
47
Making things more complex, the broader concept of “violent extremism” was used by the Obama Administration.
According to the administration, “violent extremists” are “individuals who support or commit ideologically-motivated
violence to further political goals.” See Empowering Local Partners to Prevent Violent Extremism in the United States,
August 2011, p. 1.
48
Peter R. Neumann, Prisons and Terrorism: Radicalisation and De-Radicalisation in 15 Countries, International
Centre for the Study of Radicalisation and Political Violence, London, 2010, p. 12. In its Guidebook on Extremism for
Law Enforcement, Hereinafter: Neumann, Prisons and Terrorism. The Anti-Defamation League has defined extremists
as: “people who subscribe to extreme ideologies.” The group goes on to say, “extreme ideologies are those that promote
world views so radical that most other people will not agree with them.” See Anti-Defamation League, Guidebook, p.
3.

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“Homegrown Violent Extremists” Are Not Domestic Terrorists
The FBI and DHS have popularized the phrase “homegrown violent extremist” (HVE). It
separates domestic terrorists from U.S.-based terrorists motivated by the ideologies of foreign
terrorist organizations. According to DHS and the FBI, a HVE is “a person of any citizenship
who has lived and/or operated primarily in the United States or its territories who advocates, is
engaged in, or is preparing to engage in ideologically-motivated terrorist activities (including
providing support to terrorism) in furtherance of political or social objectives promoted by a
foreign terrorist organization, but is acting independently of direction by a foreign terrorist
organization.”49 According to the FBI and DHS, an HVE is not a domestic terrorist—they are two
distinct categories of terrorist actors.50

The Lack of an Official Public List
The federal government does not generate an official and public list of domestic terrorist
organizations or individuals.51 The development of such a list may be precluded by civil liberties
concerns (i.e., inclusion in a publicly available list may impinge on a group’s exercise of free
speech or its other constitutionally protected activities). However, a lack of official lists or
processes to designate groups or individuals as domestic terrorists makes it difficult to assess
domestic terrorism trends and evaluate federal efforts to counter such threats. In 2011, an
unnamed DHS official cited in a news report stated that “unlike international terrorism, there are
no designated domestic terrorist groups. Subsequently, all the legal actions of an identified
extremist group leading up to an act of violence are constitutionally protected and not reported on
by DHS.”52 Constitutionality aside, the lack of a list may also contribute to a certain vagueness in
the public realm about which groups the federal government considers domestic terrorist
organizations. While the government does not provide an official and public list of domestic
terrorist organizations, it does include domestic terrorists (along with international terrorists) in
its Terrorist Screening Database, commonly known as the “Terrorist Watchlist.”53
The government is much less vague regarding foreign terrorist organizations. They are officially
designated as such according to a well-established legally and procedurally proscribed regimen.
According to the Department of State’s Bureau of Counterterrorism, as of August 16, 2017, the

49

This definition appears to differ from the conceptualization of “homegrown jihadists” used in this report by (1) only
including individuals not directed by a foreign organization and by (2) including all sorts of terrorists motivated by
foreign ideologies, not just violent jihadists. See Department of Homeland Security and Federal Bureau of
Investigation, Joint Intelligence Bulletin, “Use of Small Arms: Examining Lone Shooters and Small-Unit Tactics,”
August 16, 2011, p. 3.
50
Ibid.
51
See (name redacted)avita, “Does the U.S. Have Any Domestic Terrorist Groups?” Homeland Security Watch, June
29, 2010. Hereinafter: Bellavita, “Domestic Terrorist Groups.” See also R. Jeffrey Smith, “Homeland Security
Department Curtails Home-Grown Terror Analysis,” Washington Post, June 7, 2011. Hereinafter: Smith, “Homeland
Security.” David E. Heller, “Designating Domestic Terrorist Individuals or Groups,” (Master’s Thesis, Naval
Postgraduate School, 2010). Hereinafter: Heller, “Designating Domestic.”
52
Smith, “Homeland Security.”
53
Federal Bureau of Investigation, Terrorist Screening Center, “Frequently Asked Questions.” See also Timothy J.
Healy, Director, Terrorist Screening Center, Federal Bureau of Investigation, Statement before the House Judiciary
Committee, Washington, DC, March 24, 2010; Bellavita, “Domestic Terrorist Groups.” For more information on the
Terrorist Screening Database, see CRS Report R44678, The Terrorist Screening Database and Preventing Terrorist
Travel, by (name redacted), (name redacted), and (name redacted)
.

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Secretary of State had designated 61 foreign terrorist organizations according to Section 219 of
the Immigration and Nationality Act, as amended.54

Toward a Practical Definition: Threats Not Groups
As discussed above, DOJ and the FBI do not list domestic terrorist organizations publicly and
officially. This may complicate the understanding that federal policymakers have of what exactly
the government considers “domestic terrorism.” While not naming specific groups, DOJ and the
FBI have openly delineated domestic terrorist threats. DOJ has identified domestic terrorism
threats to include criminal activity by animal rights extremists, ecoterrorists, anarchists, antigovernment extremists such as ‘sovereign citizens’ and unauthorized militias, black separatists,
white supremacists, and abortion extremists.55
The actors who constitute each of the domestic terrorist “threats” outlined by DOJ draw upon
ideologies whose expression largely involves constitutionally protected activity. The FBI
safeguards against cases focused solely on constitutionally protected activities. All FBI
investigations have to be conducted for an authorized national security, criminal, or foreign
intelligence collection purpose.56 The purpose of an investigation may not be to solely monitor
First Amendment rights.57
However, it is unclear how DOJ or the FBI arrive at their list of domestic terrorism threats. This
poses at least two fundamental questions:


How does a particular brand of dissent become ripe for description by DOJ and
the FBI as driving a “domestic terrorism” threat?
What criteria are involved in such a process?
How many crimes or plots attributed to a specific ideology have to occur to stimulate
the identification of a new extremist threat? Is the severity of the crimes linked to an
ideology taken into consideration?

54

For the legal criteria used to designate a foreign terrorist organization, the legal ramifications of designation, and
ancillary effects of designation see Department of State, “Foreign Terrorist Organizations,” https://www.state.gov/j/ct/
rls/other/des/123085.htm.
55
Department of Justice, White Paper, p. 59. See also Federal Bureau of Investigation, “Domestic Terrorism.” In recent
years, the FBI has switched from “anti-abortion” to abortion extremism, thus including individuals who may commit
crimes to protect abortion rights. The FBI’s domestic terrorism investigations likely cover these categories as well as
lone wolves (lone offenders): extremists who commit crimes without the support of a formal organization or network.
Some lone wolves are motivated by the ideologies behind the threats outlined by DOJ, but they can fashion their own
ideologies as well. In the past, in the area of domestic terrorism, the FBI has distinguished between “special interest
terrorism” and “traditional right-wing and left-wing terrorism: “Special interest terrorism differs from traditional rightwing and left-wing terrorism in that extremist special interest groups seek to resolve specific issues, rather than effect
widespread political change. Special interest extremists continue to conduct acts of politically motivated violence to
force segments of society, including the general public, to change attitudes about issues considered important to their
causes. These groups occupy the extreme fringes of animal rights, pro-life, environmental, anti-nuclear, and other
movements.” It is unclear whether the FBI still uses the categories of “special interest,” “left-wing,” and “right-wing”
terrorism. See Jarboe, Testimony. See also Federal Bureau of Investigation, “What are Known Violent Extremist
Groups?” https://www.fbi.gov/cve508/teen-website/what-are-known-violent-extremist-groups. This is from a website
designed by the FBI to counter violent extremism. The website, titled “Don’t Be a Puppet,” addresses teenagers.
Regardless, it is one of the few publicly-available sources where the Bureau succinctly describes numerous violent
extremist groups or ideologies.
56
Federal Bureau of Investigation, Domestic Investigations and Operations Guide, redacted, October 15, 2011, p. 4-1
through p. 4-2.
57
Ibid.

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

At what point do ideologically driven domestic terrorism threats cease to exist?
Should there be a means for public petitioning of the government to eliminate
various threats as investigative priorities?

The below discussion of domestic terrorism threats does not necessarily presume the priority of
one over the other.58 It is also important to note that instances of animal rights extremism and
ecoterrorism within the last fifteen years are more readily available in the public record than
cases involving other types of domestic terrorism.59 The extensive use of such examples in this
report does not imply the prominence of animal rights extremism or ecoterrorism over other
domestic terrorist threats.

Animal Rights Extremists and Environmental Extremists
The term “animal rights extremism” covers criminal acts committed in the name of animal
rights.60 Environmental extremism—most often referred to as “ecoterrorism”—includes criminal
acts committed in the name of the environment.61 These terms are not applied to groups or
individuals involved with environmental movements or animal welfare protection/rights activism
within the “confines of civil society and the rule of law.”62
Many of the crimes committed by both animal rights extremists and ecoterrorists are perpetrated
by independent small cells or individuals who harass and intimidate their victims.63 These cells or
lone actors engage in crimes such as vandalism, theft, the destruction of property, and arson. Most
animal rights extremists and ecoterrorists also eschew physical violence directly targeting people
or animals. Regardless, crimes committed by ecoterrorists and animal rights extremists have
caused millions of dollars in property damage, and some have involved the intimidation and
harassment of victims.64 These two types of extremism are often discussed together, because the
two broader radical movements from which they draw their philosophical underpinnings have
similar beliefs and overlapping membership.
The two movements—the Animal Liberation Front (ALF) and the Earth Liberation Front (ELF)—
have the greatest reach among animal rights extremists and ecoterrorists. The ALF and the ELF
are too diffuse to be called groups. Neither the ALF nor the ELF maintains formal rosters or
leadership structures, for example.65 However, each communicates a sense of shared identity and
attracts people who commit crimes in its name. They achieve this via “above-ground” wings.
58

The discussion lists the threats in the same order as found in Department of Justice, White Paper.
People the FBI or DOJ may characterize as animal rights extremists and ecoterrorists have tended to publicize their
activities online.
60
Department of Homeland Security, “Domestic Terrorism and Homegrown.”
61
For the purposes of this report, “ecoterrorists,” “eco-extremists,” and “environmental extremists” are synonymous.
These terms and “animal rights extremism” describe individuals engaged in criminal activity in the name of radical
environmental ideologies or animal rights. It is unclear why environmental extremists are frequently dubbed
“ecoterrorists” while animal rights extremists do not have a similar commonplace usage applied to them.
62
See Kevin R. Grubbs, “Saving Lives or Spreading Fear: The Terroristic Nature of Eco-Extremism,” Animal Law, vol.
16, no. 2 (2010), p. 353-57. Hereinafter: Grubbs, “Saving Lives.”
63
See Federal Bureau of Investigation, “Putting Intel to Work against ELF and ALF Terrorists,” June 30, 2008.
Hereinafter: FBI, “Putting Intel.”
64
Ibid.
65
Both the ALF and the ELF focus on criminal activity as central tenets of their philosophies or operational guidelines,
and the FBI emphasizes that criminal activity is a key element in the identities of these movements. See FBI, “Putting
Intel.”
59

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Largely using websites, ALF and ELF supporters publish literature highlighting movement
philosophies, tactics, and accounts (press releases) of recent movement-related criminal activity.
Much of this involves protected speech and occurs in the public realm. Press releases allow
“underground” extremists to publicly claim responsibility for criminal activity in the name of
either movement while maintaining secrecy regarding the details of their operations. The ALF
and the ELF do not work alone. Members of other entities such as Stop Huntingdon Animal
Cruelty (SHAC) have committed crimes in the name of animal rights, for example.
Additional factors tangle our understanding of the ALF and the ELF. People can simultaneously
participate in both. This may partly be true because the movements are so amorphous. The two
movements also share similar agendas, and in 1993 they declared solidarity.66 All of this can play
out confusingly in the real world. For example, an individual can commit a crime and claim
responsibility for it online in the name of both the ALF and the ELF. One case especially
highlights intersections between the ALF and the ELF.
In the late 1990s and early 2000s, the FBI uncovered a network that, according to DOJ,
committed violent acts in the name of both the ALF and the ELF. The group included about 20
individuals and called itself “the Family.” It was reportedly responsible for at least 25 criminal
incidents totaling approximately $48 million in damages and disbanded at some point in 2001,
due to law enforcement pressure on the group. The Family was responsible for an arson attack in
1998 at the Vail Ski Resort. Eight simultaneous fires damaged radio towers, ski lift towers,
restaurants, and the ski patrol office at the Colorado site and totaled over $24 million in losses.67

Philosophical Underpinnings
Both the ALF and the ELF rely on and borrow from a number of philosophical underpinnings to
rationalize their beliefs and actions. These help forge a common identity among individuals in
each movement. These ideas are also key principles professed by more mainstream animal rights
or environmental activists engaged in legal protest.
The ALF: Animal Rights and Speciesism. The ALF’s moral code includes the belief that
animals possess basic inalienable rights such as life, liberty, and the pursuit of happiness, and this
suggests that animals cannot be owned. According to the ALF, the U.S. legal system—which
describes animals as property—is corrupt, and there exists a “higher law than that created by and
for the corporate-state complex, a moral law that transcends the corrupt and biased statutes of the
US political system.”68 Simply put, the rights of one species do not trump the rights of others. To
suggest otherwise is to be prejudiced, according to animal rights adherents.
For the ALF and other animal rights supporters, the favoring of one species, particularly humans,
over others has a name: speciesism. For the ALF, speciesism is a “discriminatory belief system as
66

U.S. Congress, Senate Committee on Environment and Public Works, “Statement of Carson Carroll, Deputy
Assistant Director, Bureau of Alcohol, Tobacco, Firearms, and Explosives,” Eco-Terrorism Specifically Examining the
Earth Liberation Front and the Animal Liberation Front, 109th Cong., 1st sess., May 18, 2005, S. Hrg. 109-947
(Washington: GPO, 2007), p. 43. Hereinafter: Statement of Carson Carroll.
67
Federal Bureau of Investigation, “Operation Backfire: Help Find Four Eco-Terrorists,” November 19, 2008;
Department of Justice, “Eleven Defendants Indicted on Domestic Terrorism Charges,” press release, January 20, 2006.
Hereinafter: Department of Justice, “Eleven Defendants.” See also United States v. Joseph Dibee et al, Sentencing
Memorandum, CR 06-60069-AA, CR 06-60070-AA, CR 06-60071-AA, CR 06-60078-AA, CR 06-60079-AA, CR 0660080-AA, CR 06-60120-AA, CR-06-60122-AA, CR-06-60123-AA, CR-06-60124-AA, CR-06-60125-AA, CR60126-AA, U.S. District Court, District of Oregon, May 4, 2007, pp. 6, 8, 19, 20-21. Hereinafter: U.S. v. Dibee et al.
68
North American Animal Liberation Press Office, “History of the Animal Liberation Movement.” Hereinafter:
NAALPO, “History.”

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ethically flawed and philosophically unfounded as sexism or racism, but far more murderous and
consequential in its implications.”69 Thus, the movement couches the theft or illegal release of
animals used in research or for economic gain as “liberation.” The ALF views the destruction of
laboratory infrastructure or tools as the elimination of items used to enslave species who have the
same rights as humans. Intimidation of scientists and employees of businesses tied to animal
research or testing is rationalized as confrontation with “oppressors” or those who, in the eyes of
movement adherents, abuse and murder animals.70
The ELF: An Ideological Mélange. Ecoterrorists are motivated by a mélange of environmental
philosophies. There is no single formula for what constitutes the ideological makeup of an ELF
follower, but several concepts likely play key roles in the movement. These are biocentrism, deep
ecology, social ecology, and green anarchism. Biocentrism argues for the equality of all
organisms.71 Deep ecology suggests that all species are part of “the larger super-organism that is
nature.”72 It criticizes industrialization and views modern human impact on the earth as negative
and hearkens back to small communities centered on subsistence agriculture.73 Social ecology
suggests that hierarchical human society leads to social inequalities and environmental harm.
Green anarchism ascribes environmental harm to civilization and domestication and embraces the
notion of “rewilding,” or rejecting civilization and returning to a hunter-gatherer state to preserve
one’s natural surroundings.74

Anarchist Extremists
According to the FBI, anarchist extremists commit crimes in the name of anarchist ideals.75 These
ideals include belief that
individual autonomy and collective equality are fundamental and necessary for a
functional, civilized society. [Anarchism] resists the existing hierarchical structure of
society that gives some people authority and control over others. [According to
anarchists] authority imbues power, and power always is used in illegitimate and selfserving ways by those who have it.76

Anarchist extremists as well as anarchists engaging in constitutionally protected activity can
oppose government, business, or social interests that they view as dangerous. As this suggests,
anarchists advocate some form of revolution that realigns authority in the societies they desire to
69

Steven Best and Anthony J. Nocella, II, “Behind the Mask: Uncovering the Animal Liberation Front,” in Terrorists
or Freedom Fighters? Reflections on the Liberation of Animals, ed. Steven Best and Anthony J. Nocella, II (New York:
Lantern Books, 2004), p. 24. Hereinafter: Best and Nocella, “Behind the Mask.” Best reportedly advises NAALPO, see
http://naalpo.posterous.com/our-task-new-essay-by-press-office-advisor-st. P. Michael Conn and James V. Parker, The
Animal Research War (New York: Palgrave Macmillan, 2008), p. xix. Hereinafter: Conn and Parker, The Animal. See
also NAALPO, “History” which excerpts Best and Nocella’s work.
70
NAALPO, “History.”
71
Stefan H. Leader and Peter Probst, “The Earth Liberation Front and Environmental Terrorism,” Terrorism and
Political Violence, vol. 15, no. 4 (Spring/Summer 2005), pp. 39-40. Hereinafter: Leader and Probst, “The Earth
Liberation Front.”
72
Conn and Parker, The Animal, xx.
73
Leader and Probst, “The Earth Liberation Front,” pp. 39-40.
74
Sean Parson, “Understanding the Ideology of the Earth Liberation Front,” Green Theory and Praxis: The Journal of
Ecopedagogy, vol. 4, no. 2 (2008), pp. 54-58.
75
Ibid.
76
Randy Borum and Chuck Tilby, “Anarchist Direct Actions: A Challenge for Law Enforcement,” Studies in Conflict
and Terrorism, vol. 28, no. 3, (2005), p. 202. Hereinafter: Borum and Tilby, “Anarchist Direct Action.”

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transform. However, adherents cannot agree to a single means for attaining revolutionary
change.77
As one may assume, anarchist activity is decentralized. In fact, a basic, temporary organizational
structure—the affinity group—likely plays a larger role in shaping the work of U.S. anarchists
than any formal long-lasting entities or networks.78 Affinity groups are “autonomous militant
unit[s] generally made up of between five-to-twenty individuals who share a sense of the causes
worth defending and the types of actions they prefer to engage in. The decision-making process is
anarchist, that is to say, egalitarian, participatory, deliberative, and consensual.”79 An affinity
group often consists of a circle of friends. The friends coalesce around a specific objective and
break apart when they achieve their desired ends. Individual groups can band together in
“clusters” and clusters can coordinate their efforts, if need be.80 The efforts can be legal or illegal,
violent or nonviolent, covert or open. These structures have a long history among anarchists, but
other movements use them as well.81 Also, anarchists can engage in what they call “black bloc”
tactics. These involve secretive planning for public—often criminal—activity in which
participants, typically dressed in black, act en-masse.82 Adding to the sprawling nature of the
anarchist movement, some adherents also participate in the ALF and the ELF. These three
movements share general philosophical tenets such as opposition to globalization and
capitalism.83
“Antifa”
In the aftermath of the violence related to protests in Charlottesville, VA, on August 12, 2017, there has been media
attention devoted to the confrontational tactics of antifascist protesters known as “Antifa.” Antifa beliefs can dovetail
with the broad anti-government and anti-capitalist views that are part of anarchism.84 One observer has described
Antifa as, “a radical pan-leftist politics of social revolution applied to fighting the far right. Its adherents are
predominantly communists, socialists and anarchists who reject turning to the police or the state to halt the advance
of white supremacy.”85 Antifa beliefs appear to inspire autonomous groups to track the activities of neo-Nazis, and
most “anti-fascist organizing is nonviolent.”86 However, some Antifa protesters are willing to violently clash with
people publicly advocating what Antifa protesters would see as fascist views, particularly white supremacists.87 Antifa
protesters characterize such violence targeting people as defensive.88

77

Ibid., p. 203.
Borum and Tilby, “Anarchist Direct Action,” p. 207.
79
Francis Dupuis-Déri, “Anarchism and the Politics of Affinity Groups,” Anarchist Studies, vol. 18, no. 1 (2010),
p. 41. Hereinafter: Dupuis-Déri, “Anarchism.”
80
CrimethInc. Workers’ Collective, Recipes for Disaster: An Anarchist Cookbook, (Olympia, WA: CrimethInc.
Workers’ Collective, 2004), pp. 28-34. Hereinafter: Anarchist Cookbook.
81
Dupuis-Déri, “Anarchism,” p. 43.
82
Anarchist Cookbook, pp. 127-130.
83
Borum and Tilby, “Anarchist Direct Action,” p. 208.
84
“Anarchist Extremists: Antifa,” State of New Jersey Office of Homeland Security and Preparedness, June 12, 2017.
Hereinafter: “Anarchist Extremists: Antifa.” Breanna Cammeron, “Antifa: Left-Wing Militants on the Rise,” BBC
News, August 14, 2017.
85
Mark Bray, “Who Are the Antifa?” Washington Post, August 16, 2017.
86
Ibid.
87
See “Anarchist Extremists: Antifa.”
88
Sara Ganim and Chris Welch, “Unmasking the Leftist Antifa Movement,” CNN, August 20, 2017. They have also
engaged in property destruction.
78

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The FBI has described anarchist extremists as typically being “event driven,” meaning
they show up at political conventions, economic and financial summits, environmental
meetings, and the like. They usually target symbols of Western civilization that they
perceive to be the root causes of all societal ills—i.e., financial corporations, government
institutions, multinational companies, and law enforcement agencies. They damage and
vandalize property, riot, set fires, and perpetrate small-scale bombings. Law enforcement
is also concerned about anarchist extremists who may be willing to use improvised
explosives devices or improvised incendiary devices.89

Anarchist extremists in the United States have been involved in illegal activity during mass
protests surrounding events such as the 1999 World Trade Organization Ministerial Conference in
Seattle, WA.
Anarchist extremists reportedly committed crimes during the 2008 Republican National
Convention in St. Paul, MN.90 To coordinate their protests during the convention, some anarchists
formed what they called the “RNC Welcoming Committee” (RNCWC).91 In September 2007, the
RNCWC developed a plan to broadly organize the activities of affinity groups intending to
disrupt the convention. Law enforcement infiltrated and undermined these efforts, arresting 800
people, including eight involved with the RNCWC.92 Initially, in Minnesota state court, the eight
“had been charged with felonies: first-degree damage to property and second-degree conspiracy
to riot. Prosecutors added a more serious charge of conspiracy to riot in furtherance of terrorism,
which was later dismissed.”93 Five of the eight pled guilty to gross misdemeanor charges in 2010.
The others had all of the charges they faced dismissed.94
On April 30, 2012, five men who reputedly had anarchist sympathies were arrested for
purportedly scheming to blow up a bridge near Cleveland, OH.95 One was convicted on charges
related to the plot. The four others pled guilty.96 The plot was apparently timed to coincide with
peaceful protest activity arranged by Occupy Cleveland, an offshoot of the Occupy Wall Street
movement. Occupy Cleveland representatives stated that the would-be bombers “were in no way
representing or acting on behalf of Occupy Cleveland.”97 An FBI sting operation led to the
89

Federal Bureau of Investigation, “Anarchist Extremism.”
Ibid. For information on reported anarchist criminal activity related to the 2008 Republican National Convention, see
Department of Justice, “Michigan Man Sentenced for Possessing Molotov Cocktails,” press release, March 10, 2009;
Department of Justice, “Texas Man Sentenced on Firearms Charges Connected to the Republican National
Convention,” press release, May 21, 2009; Department of Justice, “Austin, Texas Man Sentenced for Possessing
Molotov Cocktails During the Republican National Convention,” press release, May 14, 2009. For information on a
matter possibly related to the anarchist criminal activity at the 2008 convention, see James C. McKinley, Jr., “Anarchist
Ties Seen in ‘08 Bombing of Texas Governor’s Mansion,” New York Times, February 22, 2011.
91
For an archived version of the group’s website see http://web.archive.org/web/20080907081250/http://
www.nornc.org./.
92
Pat Pheifer, “Guilty Pleas Close Book on ‘08 Convention Protests,” Minneapolis-St. Paul Star Tribune, October 19,
2010. Hereinafter: Pheifer, “Guilty Pleas.” See also Fred Burton and Scott Stewart, “The Lessons of St. Paul,”
STRATFOR, September 10, 2008.
93
Pheifer, “Guilty Pleas.”
94
Ibid.
95
Department of Justice, “Five Men Arrested in Plot to Bomb Ohio Bridge,” press release, May 1, 2012. Hereinafter:
Department of Justice, “Five Men.” David Ariosto, “5 Arrested in Alleged Plot to Blow Up Cleveland-Area Bridge,”
CNN, May 1, 2012.
96
Kim Palmer, “‘Anarchist’ Convicted in Ohio Bridge Bomb Plot,” Reuters, June 13, 2013.
97
Henry J. Gomez, “Bridge Bomb Plot: Suspects Were Active in Occupy Cleveland, Even As Movement Slowed to a
Crawl,” Cleveland Plain Dealer, May 2, 2012.
90

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quintet’s arrest.98 Purportedly, the group relied on an undercover FBI employee to supply them
with two inert bombs that the conspirators believed were functional.99
Criminal acts involving anarchist extremists do not have to be event-driven. For example, Eric G.
King pled guilty to using explosive devices to commit arson in a failed 2014 attempt to ignite a
fire at the Kansas City, MO, office of U.S. Representative Emanuel Cleaver II. The incident
occurred when the office was unoccupied, but King had posted violent commentary regarding
police to social media.100
DHS noted that anarchist extremists had set fires at urban development project sites in Vancouver,
Canada, and Seattle, WA, in 2013. Anarchist extremists are also suspected in a similar incident
that occurred in Grand Rapids, MI in 2011.101 These attacks followed instances of what DHS
characterized as “lower-level criminal activity or mischief involving anarchist or ‘antigentrification statements.’”102
In another case that was not event-driven, Joseph Konopka, the self-dubbed “Dr. Chaos,”
allegedly led a group of boys he called “The Realm of Chaos” in a series of crimes involving
vandalism to radio and cell phone towers in the late 1990s and early 2000s. In 2002, he was
arrested in Chicago for storing more than a pound of deadly cyanide powder in a passageway in a
Chicago Transit Authority subway tunnel.103 He had obtained the material (potassium cyanide and
sodium cyanide) from an abandoned warehouse.104 In 2002, Konopka pled guilty in federal court
to possessing chemical weapons, and in 2005 he pled guilty to 11 felonies, including conspiracy,
arson, creating counterfeit software, and interfering with computers in Wisconsin.105

White Supremacist Extremists
The term “white supremacist extremism” (WSE) describes people or groups who commit
criminal acts in the name of white supremacist ideology. According to media sources, in May
2017, FBI and DHS released a joint intelligence bulletin reputedly stating that white supremacists
“were responsible for 49 homicides in 26 attacks from 2000 to 2016 ... more than any other
domestic extremist movement.”106
98

Department of Justice, “Five Men.”
Ibid. Four of the conspirators pled guilty “to conspiracy to use weapons of mass destruction, attempted use of
weapons of mass destruction, and malicious use of an explosive device to destroy property used in interstate
commerce.” See Department of Justice, “Three Men Sentenced to Prison for Roles in Plot to Bomb Ohio Bridge,” press
release, November 20, 2012. A fifth was “convicted of conspiracy to use a weapon of mass destruction and other
charges.” See Kim Palmer, “‘Anarchist’ Convicted in Ohio Bridge Bomb Plot,” Reuters, June 13, 2013.
100
Tony Rizzo, “Man Who Threw Molotov Cocktails at Rep. Emanuel Cleaver’s KC Office Gets 10-Year Sentence,”
Kansas City Star, June 28, 2016; Department of Justice, “KC Man Pleads Guilty to Throwing Molotov Cocktails at
Congressional Office,” press release, March 3, 2016.
101
Department of Homeland Security, “Self-Identified Anarchist Extremists Target Urban ‘Gentrification’ Sites with
Arson,” July 23, 2013.
102
Ibid.
103
Juliet Williams, Federal appeals Court Overturns Dr. Chaos Conviction,” Associated Press, May 31, 2005; Mike
Robinson, “Federal Prosecutors Want ‘Dr. Chaos’ to Remain Locked Up,” Associated Press, March 13, 2002; Meg
Jones and Jesse Garza, “‘Anarchist’ Charged Over Cache of Cyanide,” Milwaukee Journal Sentinel, March 12, 2002.
104
“Man Pleads Guilty to Storing Cyanide,” Associated Press, November 21, 2002.
105
“Judge Sentences ‘Dr. Chaos’ to Prison for Damage to Wisconsin Power Systems, Associated Press, November 30,
2005.
106
Jana Winter, “FBI and DHS Warned of Growing Threat From White Supremacists Months Ago,” Foreign
Policy.com, August 14, 2017.
99

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At its core, white supremacist ideology purports that the white race ranks above all others. WSE
draws on the constitutionally protected activities of a broad swath of racist hate-oriented groups
active in the United States ranging from the Ku Klux Klan to racist skinheads. Some of these
groups have elaborate organizational structures, dues-paying memberships, and media wings.
Additionally, many individuals espouse extremist beliefs without having formal membership in
any specific organization.
A large proportion of white supremacists dualistically divide the world between whites and all
other peoples who are seen as enemies.107 Particular animus is directed toward Jews and African
Americans. In fact, a common racist and revisionist historical refrain is that the civil rights
movement succeeded only because Jews orchestrated it behind the scenes.108
Scholars indicate that white supremacists believe in racial separation and that society
discriminates against them. To them, whites have lost “ground to other groups and ... extreme
measures are required to reverse the trend.”109 All of this has been encapsulated in a slogan
known as the “Fourteen Words”: “We must secure the existence of our race and a future for white
children.” This was coined by David Lane, a member of a violent terrorist group active in the
1980s. The Fourteen Words have been described as “the most popular white supremacist slogan
in the world.”110
Neo-Nazism and its obsession with Adolph Hitler and Nazi Germany is also a prominent
component of white supremacist extremism in the United States.111 The father of American neoNazism, George Lincoln Rockwell, became publicly active in the late 1950s. According to one
scholar, Rockwell laid down three concepts that have shaped neo-Nazism ever since. For his
followers, he reconfigured the racial notion of “white,” broadening it beyond “Aryan” to include
people of Southern and Eastern European descent. Additionally, Rockwell denied the Holocaust.
He also encouraged tying neo-Nazism to religion, and some of his followers took up the obscure
creed of Christian Identity.112

Conflict and Conspiracy
Aside from racial superiority, a dualistic view of the world, and neo-Nazism, at least two other
broad concepts shape white supremacy in the United States. They are the inevitability of violent
107

Chip Berlet and Stanislav Vysotsky, “Overview of U.S. White Supremacist Groups,” Journal of Political and
Military Sociology, vol. 34, no. 1 (Summer 2006), p. 13. Hereinafter: Berlet and Vysotsky, “Overview.”
108
Leonard Zeskind, Blood and Politics: The History of the White Nationalist Movement from the Margins to the
Mainstream (New York: Farrar, Straus, and Giroux, 2009), p. 40. Hereinafter: Zeskind, Blood and Politics.
109
Rory McVeigh, “Structured Ignorance and Organized Racism in the United States,” Social Forces, vol. 82, no. 3
(March 2004), pp. 898-899.
110
Anti-Defamation League, Guidebook, p. 16. Lane died in 2007 while serving 190 years in prison for his
involvement with a terrorist group named the Order. See “Founder of Terrorist Group Dies in Prison,” Terre Haute
Tribune-Star, May 29, 2007, http://tribstar.com/local/x1155692948/Founder-of-terrorist-group-dies-in-prison. Among
other writings, Lane also drafted an influential racist ideological tract titled The 88 Precepts.
111
Anti-Defamation League, Guidebook, p. 15.
112
Fredrick J. Simonelli, “The Neo-Nazi Movement,” Southern Poverty Law Center. See also Charles S. Clark, “An
American Nazi’s Rise and Fall,” American History, vol. 40, no. 6 (February 2006), pp. 60-66; Simonelli, “The
American Nazi Party,” Historian, vol. 57, no. 3 (Spring 1995), pp. 553-566. A follower assassinated Rockwell in 1967.
For information on Christian Identity, see Kevin Borgeson and Robin Valeri, Terrorism in America (Sudbury, MA:
Jones and Bartlett, 2009), pp. 47-72; Martin Durham, “Christian Identity and the Politics of Religion,” Totalitarian
Movements and Political Religions, vol. 9, no. 1 (March 2008), pp. 79-91; Tanya Telfair Sharpe, “The Identity
Christian Movement: Ideology of Domestic Terrorism,” Journal of Black Studies, vol. 30, no. 4 (March 2000), pp. 604623; Anti-Defamation League, “Christian Identity.”

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conflict, and a belief that conspiracies hostile to white supremacy shape the existing world.113 It
can be said that WSE broadly shares these concepts with the militia movement (discussed below).
The FBI has stated that white supremacists “commonly anticipate” waging war against their
opponents.114 For example, the inevitability of RAHOWA—an acronym for “racial holy war”—is
a central tenet of the neo-Nazi Creativity Movement, which has its roots in the Church of the
Creator, a racist group founded by Ben Klassen in 1973.115 Klassen, who committed suicide in
1993, argued that whites had no choice but to wage war against non-whites.116 Likewise, some
white supremacists use racism to interpret apocalyptic imagery from Norse mythology embodied
in Odinism.117 Most Odinists are not racists, however.118
Conspiracism has been defined as “the idea that most major historic events have been shaped by
vast, long-term, secret conspiracies that benefit elite groups and individuals.”119 Conspiracy
theories are not the province of a particular movement or group. Regardless, conspiracy theories
can particularly shape the outlooks and actions of white supremacist extremists. Media sources
have stated that Richard Poplawski—convicted of shooting and killing three Pittsburgh police
officers in April 2009—believed that a Zionist conspiracy controlled government and major
corporations in the United States.120
As in Poplawski’s example, anti-Semitism plays a prominent role in the racist conspiracies of
many white supremacists.121 Many anti-Semites—as well as anti-government extremists—believe
in something they call the Zionist Occupied Government (ZOG).122 ZOG refers to the federal
government, which adherents contend is “controlled or manipulated by international Jewish
interests.”123 On its website, one WSE group sold versions of a video game titled “ZOG’s
Nightmare.” Gameplay involves shooting nonwhites while being chased by a police agency
113

Berlet and Vysotsky, “Overview,” pp. 12-13 highlights dualism, conspiracism, and apocalypticism as key themes.
The Bureau has noted that “warfare” is reflected in beliefs drawn from Christian Identity, the Creativity Movement,
neo-Nazism, and Odinism. See Federal Bureau of Investigation, White Supremacist Recruitment of Military Personnel
since 9/11, July 7, 2008, p. 4. Hereinafter: Federal Bureau of Investigation, White Supremacist.
115
After Klassen’s 1993 death, the Church of the Creator was revived in an altered form by Matt Hale. For more
information see Dobratz, “The Role,” p. 290; and Federal Bureau of Investigation, White Supremacist, p. 4.
116
Ben Klassen, “RAHOWA: The Fighting Slogan of the White Race,” Racial Loyalty, no. 32 (February 1986).
117
Federal Bureau of Investigation, White Supremacist, p. 4. Odinism has been defined as either a combination of old
Norse religion and Christianity or a belief system that draws exclusively on Nordic mythology. See Jonathan White,
“Political Eschatology: A Theology of Antigovernment Extremism,” The American Behavioral Scientist, vol. 44, no. 6,
(February 2001), p. 939.
118
Berlet and Vysotsky, “Overview,” p. 30.
119
Berlet and Vysotsky, “Overview,” p. 12. For more on conspiracy theories and terrorism see Jamie Bartlett and Carl
Miller, The Power of Unreason: Conspiracy Theories, Extremism, and Counter-Terrorism, Demos, London, August
29, 2010. Barlett and Miller (p. 24.) suggest that conspiracy theories “are one of a number of factors that can lead to
extremism, and can turn extremism to violence.”
120
Timothy McNulty, Paula Reed Ward and Sadie Gurman, “Jury Decides Poplawski Should Die for Killing 3
Officers,” Pittsburgh Post-Gazette, June 28, 2011. Hereinafter: McNulty et al., “Jury Decides.” See also AntiDefamation League, “Richard Poplawski: The Making of a Lone Wolf,” April 8, 2009. Hereinafter: Anti-Defamation
League, “Richard Poplawski.” Sean D. Hamill, “Man Accused in Pittsburgh Killings Voiced Racist Views Online,”
New York Times, April 7, 2009. Hereinafter: Hamill, “Man Accused.”
121
Berlet and Vysotsky, “Overview,” p. 13.
122
Also seen as “Zionist Occupation Government.”
123
Institute for Intergovernmental Research, Investigating Terrorism, p. 93; Mattias Gardell, Gods of the Blood: The
Pagan Revival and White Separatism (Durham, NC: Duke University Press, 2003), pp. 11, 54, 68-69. Hereinafter:
Gardell, Gods.
114

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controlled by Jews.124 Racists explain all sorts of personal or social grievances by invoking
ZOG.125 One scholar has described ZOG as
an omnipresent and omnipotent cabal involving at its heart varying constellations of
Jews, Illuminati, Freemasons, plutocrats, and multinational corporations. It operates
through many social ‘front’ institutions, from the United Nations to Parent-Teacher
Associations.... ZOG can be used to explain not only the existence of affirmative action,
environmental pollution, and pornography but also why a certain individual made poor
grades in school, lost his job, or seems unable to find a partner.126

According to adherents, ZOG is said to control the media, arts, religion, science, and education.127

Loss of Prominent Leaders and Decline of their Groups
In the 1980s and 1990s, a small number of figures dominated white supremacist circles. They
were intimately linked to their own relatively cohesive organizations. By the early 2000s, these
groups fragmented as they lost their leaders.
Two particularly well-known white supremacist figures died in the early 2000s. William Pierce,
head of the National Alliance, died in 2002. Richard Butler, leader of Aryan Nations, died in
2004. Both Pierce and Butler articulated clear ideologies that attracted followers and drew upon
resources such as rural headquarters/compounds to sustain their organizations.128 By the early
2000s, the National Alliance even had a substantial revenue stream estimated at $1 million
annually generated from a publishing company and record labels it owned as well as dues.129 The
deaths of Butler and Pierce exacerbated the downfall of both organizations. The decline of these
groups also resulted from a number of other forces, such as infighting among members and
pressure from law enforcement and watchdog groups.130 Other groups have emerged since to
promote white supremacist ideas. Several movements espousing such views participated in the
August 2017 rally in Charlottesville, VA, that led to violence mentioned earlier.131
Two prominent white supremacist movements are discussed below.

National Socialist Movement (NSM)
One long-standing white supremacist organization active in the United States is the National
Socialist Movement (NSM). It has benefitted from the decline of other groups as well as new
leadership in the form of Jeff Schoep.132 The NSM also capitalized on the expansion of the
124

Anti-Defamation League, The National Socialist Movement.
Gardell, Gods, p. 68.
126
Ibid.
127
Ibid.
128
Freilich, Chermak, and Caspi, “Critical Events,” 511.
129
Ibid., pp. 512, 513.
130
Ibid., p. 516.
131
Groups such as Vanguard America (started in 2014), Identity Evropa (founded in 2016), and the Traditionalist
Worker Party (begun in 2015) reportedly participated. “Various Far-Right Extremist Groups Joined at Virginia Rally,”
Associated Press, August 15, 2017; Terence Cullen, “Vanguard America, Group Charlottesville Driver James Fields Jr.
Marched with, Has Increasingly Become a Neo-Nazi Voice,” New York Daily News, August 13, 2017; Hailey BransonPotts, “In Diverse California, a Young White Supremacist Seeks to Convert Fellow College Students,” Los Angeles
Times, December 7, 2016; Ralph Ellis, At Least 7 People Injured at Sacramento Rally, Authorities Say,” CNN, June 27,
2016.
132
Anti-Defamation League, American Stormtroopers: Inside the National Socialist Movement, (2008), p. 3.
(continued...)
125

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Internet in the early 2000s. The group, which emerged in 1974, is a descendant of the American
Nazi Party, and until the 1990s and early 2000s “it operated only on the fringes of the neo-Nazi
movement.”133 As of 2008, the group had around 500 members and close associates throughout
the United States.134 The NSM is flexible about membership, allowing its members to also
participate in other white supremacist organizations.135
Individuals allegedly tied to the NSM at some point in their lives have run afoul of the law.




In Minnesota in April 2012, Joseph Benjamin Thomas was indicted on drugrelated charges, and Samuel James Johnson was indicted on weapons-related
charges. Purportedly the two were tied to NSM—at one point Johnson had
allegedly served as its leader in Minnesota. The duo had reportedly formed their
own white supremacist group, gathering weapons and ammunition and planning
to attack the government and other targets.136 In June 2012, Johnson pled guilty
to “one count of being a felon in possession of firearms.”137 In July 2012,
Thomas pled guilty to “possession with intent to distribute more than 50 grams of
high-purity methamphetamine.”138
William White, a onetime member of the NSM and founder of his own white
supremacist organization, has faced charges in several criminal cases. In
September 2014, he was found guilty on charges related to a December 2013
indictment that included “five counts of making threats in aid of extortion over
the Internet and one count of the unlawful use of identification information in
furtherance of those offenses.”139 He threatened a Florida judge, a state attorney,
and an FBI agent, with kidnapping, torture, rape, and murder. According to DOJ,
White included the families of these individuals in his threats. The officials that
White threatened had been involved in prosecuting suspects tied to the American
Front, a white supremacist organization in Florida. White apparently hoped that
his threats would somehow secure the release of the American Front suspects.140
In January 2011, White was convicted141 of soliciting violence online against the
jury foreman in U.S. v. Matthew Hale.142 In April 2011, a federal judge reversed

(...continued)
Hereinafter: Anti-Defamation League, American Stormtroopers.
133
Ibid.
134
Ibid.
135
Southern Poverty Law Center, “National Socialist Movement.”
136
Department of Justice, “Mendota Heights Man Indicted for Distributing Methamphetamine,” press release, April 27,
2012; Department of Justice, “Austin Felon Indicted for Possessing Firearms,” press release, April 27, 2012; Amy
Forliti, “Affidavit: 2 Men With Supremacist Ties Had Weapons,” Associated Press, April 27, 2012.
137
Department of Justice, “Austin Felon Pleads Guilty to Possessing an Assault Rifle,” press release, June 6, 2012.
138
Department of Justice, “Mendota Heights Man Pleads Guilty to Possessing Methamphetamine,” press release, July
11, 2012.
139
Department of Justice, “Neo-Nazi Sentenced for Sending Gruesome Threats to Florida Officials and Their
Families,” press release, November 21, 2014; Department of Justice, “White Supremacist Charged with Sending Online
Threatening Communications to a Florida Judge, State Attorney, and Task Force Agent,” press release, December 11,
2013.
140
Ibid.
141
Department of Justice, “Self-Proclaimed White Supremacist William White Convicted of Soliciting Violence
Against Hale Jury Foreman,” press release, January 5, 2011.
142
Matthew Hale was convicted of soliciting the murder of U.S. District Judge Joan Humphrey Lefkow. In the mid
1990s, Hale revived the Church of the Creator fortunes. He changed the organization’s name to the World Church of
(continued...)

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White’s conviction. Upon appeal, the conviction was reinstated.143 In an
unrelated case, in December 2009, White was convicted of four counts of
communicating threats in interstate commerce and one count of witness
intimidation. One of the convictions for communicating threats in interstate
commerce was later reversed.144 The witness intimidation charges involved White
reportedly attempting to “delay or prevent the testimony” of African Americans
in a discrimination case.145 According to publicly available information, in 2005
and 2006 White was involved with NSM, for a time serving as its national
spokesman.146 His activity with NSM ceased after he had a falling out with
Schoep.147

Racist Skinheads
In the United States, racist skinheads have a legacy stretching back to the 1980s.148 However,
skinhead culture originated in the United Kingdom in the late 1960s and today has a global
reach.149 Since the early 2000s, the movement in the United States has been characterized by a
proliferation of regional groups or crews rather than a united core organization.150 In law
enforcement circles, racist skinheads have a reputation for violence. This is “reinforced by hatefilled white power music and literature.” “[T]hey foster [their reputed toughness] through their

(...continued)
the Creator, and according to a watchdog group, by 2002 it had more chapters in the United States than any other neoNazi organization. Judge Lefkow had originally ruled in favor of Hale in a trademark infringement case involving the
name “World Church of the Creator.” Her ruling was reversed on appeal, and as a result, she had to enforce the higher
court’s reversal. Via email and during a conversation, Hale discussed with his security chief the idea of killing Lefkow.
Hale did not know that his security chief was an FBI informant. In 2003, Hale was arrested for soliciting the murder of
Judge Lefkow, and this, as well as his subsequent conviction on charges related to the case, hastened a downturn in
fortune for his World Church of the Creator. Hale is serving a 40-year prison term. After another name change, the
group—currently known simply as the Creativity Movement—shows signs of revival under new leadership. See
Michael, Theology of Hate, pp. 120-133, 173-188; Chris Dettro, “Follow-Up File: White Supremacist Finds Quiet Life
in Prison,” The State Journal-Register, Springfield, Il, October 25, 2010; Federal Bureau of Investigation, “A Different
Breed of Terrorist,” June 6, 2004.
143
Department of Justice, “White Supremacist William White Sentenced to 42 Months in Prison for Soliciting
Violence Against Hale Jury Foreman,” press release, February 20, 2013; Laurence Hammack, “Judge Tosses William
A. White Verdict,” The Roanoke Times, April 20, 2011.
144
Department of Justice, “Roanoke, Virginia Neo-Nazi Sentenced for Threats, Witness Intimidation,” press release,
April 14, 2010.
145
Ibid. See also Laurence Hammack, “Former Neo-Nazi Leader Gets 3 More Months in Prison,” October 23, 2012.
146
Laurence Hammack, “White’s Life on Fringe Puts Him at Center of Storm,” The Roanoke Times, July 26, 2009.
147
Ibid; Southern Poverty Law Center, “Bill White,” 2011. For other cases involving individuals allegedly tied to
NSM, see Department of Justice, “Valley Man Enters Guilty Plea for Possession and Transport of an Improvised
Explosive Device,” press release, September 27, 2011; Department of Justice, “Valley Man Indicted for Possessing and
Transporting Improvised Explosive Devices,” press release, January 26, 2011, http://phoenix.fbi.gov/dojpressrel/
pressrel11/px012611.htm; Rudabeh Shahbazi, “Documents Show Apache Junction Man Planned To Take IEDs to the
Border,” ABC 15; Federal Bureau of Investigation, “Domestic Terrorism: Tip Leads to Sting, Prison for Plotter,”
November 29, 2006.
148
Serge F. Kovaleski, “American Skinheads: Fighting Minorities and Each Other,” Washington Post, January 16,
1996; Southern Poverty Law Center, Skinheads in America: Racists on the Rampage, p. 3. Hereinafter: Southern
Poverty Law Center, Skinheads.
149
Ibid.
150
Ibid., p. 13; Federal Bureau of Investigation, Rage and Racism, p. 8.

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appearance (shaved heads or close-cropped hair, white power tattoos) and dress (bomber jackets,
‘braces’ (suspenders), steel-toed boots.)”151
Skinheads emerged as a non-racist movement among British working-class youth in the late
1960s. These early skinheads rejected the hippie lifestyle and embraced elements of Jamaican
culture, particularly reggae and ska music. As immigration from South Asia to the UK grew, some
white British skinheads embraced racism and neo-Nazism. This racist skinhead variant of the
subculture materialized in the U.S. Midwest and in Texas in the early 1980s.152
In the mid-1990s, many U.S.-based racist skinhead groups allied with one another to form the
Hammerskin Nation (HSN). HSN eventually developed chapters throughout the United States
and in Europe. It had its own annual meeting/concert called Hammerfest, ran a record label, and
had a publishing company. In the early 2000s, other groups such as the Outlaw Hammerskins,
Hoosier State Hammerskins, and Ohio State Skinheads challenged HSN for preeminence. These
groups saw HSN as “elitist.”153
In January 2010, the FBI released a bulletin that, among other things, emphasized that some racist
skinheads formed the most violent segment of WSE adherents.154 This supported the findings in a
2008 FBI assessment.155 Between 2007 and 2009, skinheads were involved in 36 of the 53 violent
incidents the FBI identified in the United States as being tied to WSE proponents.156 The Bureau
has stated that “violence is an integral part of the racist skinhead subculture.”157 Elements within
the fractious movement even target one another.158 These criminal acts are typically unrehearsed
and opportunistic, targeting nonwhites and “other religious and social minorities.”159
At least one exception involved greater levels of planning. One man was convicted and two
others pled guilty in a Connecticut case that involved the illegal sale of firearms and homemade
grenades. The scheme included multiple meetings between late 2008 and early 2010 to negotiate
the transactions, prepare the firearms, and assemble the grenades. The trio was tied to a skinhead
group known as Battalion 14 (originally called the Connecticut White Wolves). They sold the
weapons to a convicted felon working as an FBI cooperating witness. The informant posed as a
member of the Imperial Klans of America, a Ku Klux Klan organization. Two others in the case,
including the leader of Battalion 14 and a man not tied to the group, were acquitted of charges.160
151

Federal Bureau of Investigation, Rage and Racism, pp. 5-6.
Michael R. Ronczkowski, Terrorism and Organized Hate Crime: Intelligence Gathering, Analysis, and
Investigations, 2nd ed. (Boca Raton, FL: CRC Press, Taylor and Francis Group, 2007), pp. 40-41. Hereinafter:
Ronczkowski, Terrorism. Southern Poverty Law Center, Skinheads, pp. 3-4.
153
Southern Poverty Law Center, Skinheads, p. 5.
154
Federal Bureau of Investigation, White Supremacist Extremist Violence Possibly Decreases But Racist Skinheads
Remain the Most Violent, January 28, 2010. Hereinafter: Federal Bureau of Investigation, White Supremacist Extremist
Violence.
155
Federal Bureau of Investigation, Rage and Racism: Skinhead Violence on the Far Right, December 10, 2008.
Hereinafter: Federal Bureau of Investigation, Rage and Racism.
156
Federal Bureau of Investigation, White Supremacist Extremist Violence, p. 4.
157
Federal Bureau of Investigation, Rage and Racism, p. 5.
158
Southern Poverty Law Center, Skinheads, pp. 5, 16.
159
Federal Bureau of Investigation, Rage and Racism, p. 5.
160
Department of Justice, “Milford Man Sentenced to 10 Years in Prison for Making Grenades and Selling Guns
Intended for White Supremacist Group,” press release, May 5, 2011, http://newhaven.fbi.gov/dojpressrel/pressrel11/
nh050511.htm; Michael P. Mayko, “Two Acquitted in White Wolves Conspiracy Case,” Connecticut Post, December
2, 2010; Michael P. Mayko, “White Wolves Called ‘Home Grown Terrorists,’” Connecticut Post, November 16, 2010;
Anti-Defamation League, “Connecticut White Supremacists Indicted on Firearms and Explosives Charges,” March 24,
(continued...)
152

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Anti-Government Extremists
As mentioned above, DOJ considers both unauthorized militias and sovereign citizens as antigovernment extremists. Neither militia membership nor advocacy of sovereign citizen tenets
makes one a terrorist or a criminal. However, in some instances both militia members and
sovereign citizens have committed crimes driven in part by their ideologies.161

Militia Extremists
The militia movement became prominent in the 1990s as a collection of armed, paramilitary
groups formed to stave off what they perceived as intrusions of an invasive government.162
Central to this is a fear of firearm confiscation by a federal government thought to be out of
control. Some adherents also believe in anti-Semitic and racist ideologies.163 Regardless, most
militia members engage in constitutionally protected activity.
Militia groups typically coalesce around a specific leader. Groups can run training compounds
where they rehearse paramilitary tactics, practice their survival skills, and receive weapons
instruction and lessons in movement ideology. Some militia groups also maintain websites for
recruitment and fundraising.164 Extremists within the movement who run afoul of law
enforcement “tend to stockpile illegal weapons and ammunition, trying illegally to get their hands
on fully automatic firearms or attempting to convert weapons to fully automatic. They also try to
buy or manufacture improvised explosive devices.”165
Segments of the militia movement believe that the U.S. government is either run by some hidden
conspiracy or is an overreaching sham. Some see a “New World Order” controlling U.S.
institutions such as the media and the federal government. They contend that this is partly
fostered by international organizations such as the United Nations. From this perspective, these
organizations sap American sovereignty. Some militia supporters believe that agents of an unauthentic “Shadow Government” are interested in seizing lawfully owned firearms as part of a
plan to undermine democracy.166 Importantly, others in the militia movement hold that the federal
government has overstepped its constitutional bounds.167 One scholar has noted that some militia

(...continued)
2010. For another case allegedly involving racist skinheads, see Amy Pavuk and Henry Pierson Curtis, “Details
Emerge in Osceola Skinhead Race-War Case,” Orlando Sentinel, May 8, 2012.
161
The material in this section describes militia extremists and sovereign citizen extremists. On occasion more broadly
anti-government extremists engage in violence but defy easy categorization. For example, in 2014, broadly antigovernment extremists Jerad and Amanda Miller (husband and wife) shot and killed two Las Vegas, NV, Metropolitan
Police Department officers. Police shot and killed the couple. Mark Berman, Las Vegas Shooters Had Expressed AntiGovernment Views, Prepared for ‘Lengthy Gun Battle,’” Washington Post, June 9, 2014.
162
Institute for Intergovernmental Research, Investigating Terrorism and Criminal Extremism: Terms and Concepts,
Version 1.0, (Tallahassee, Florida: Institute for Intergovernmental Research, 2005), p. 49; Hereinafter: Institute for
Intergovernmental Research, Investigating Terrorism.
163
Arizona Counter-Terrorism Information Center, “Sovereign Citizens and Militia Information,” August 19, 2008,
p. 1.
164
Lane Crothers, “The Cultural Foundations of the Modern Militia Movement,” New Political Science, vol. 24, no. 2
(2002), p. 231. Hereinafter: Crothers, “The Cultural.”
165
Federal Bureau of Investigation, “Domestic Terrorism: Focus on Militia Extremism,” September 22, 2011.
166
Lane Crothers, Rage on the Right: The American Militia Movement from Ruby Ridge to Homeland Security
(Lanham, MD: Rowman and Littlefield, 2003), p. 57. Hereinafter: Crothers, Rage on the Right.
167
Crothers, “The Cultural,” pp. 226-228.

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members assert that they have “the right to organize, purchase and use firearms, and enforce the
law against agents of the government who behave unconstitutionally.”168
A small minority of Americans who held anti-government fears formed militias largely in
response to two incidents in the early 1990s. These were confrontations between federal law
enforcement and private citizens at Ruby Ridge, ID, and at a site near Waco, TX.169 Both involved
warrants related to firearms violations.




In August 1992, Randy Weaver and his family were engaged in an 11-day
standoff with federal law enforcement agents. Randy Weaver had failed to appear
in court on firearms-related charges in 1991. Subsequently, an unsuccessful
operation to arrest Weaver led to the death of his 14-year-old son and a U.S.
Marshal. It also precipitated the standoff. During the standoff, Weaver and a
friend were shot and wounded. An FBI sniper also shot and killed Weaver’s wife,
Vicki.170 Weaver was eventually found guilty of failing to appear in court on the
gun charges that played a role in the standoff. In October 1993, he was sentenced
to 18 months in jail and a $10,000 fine. In 1995, Weaver received a $3.1 million
settlement in a wrongful death suit filed against the U.S. government.171 The
events at Ruby Ridge helped precipitate the militia movement, whose members
tend to view Randy Weaver as a hero and demonize the federal government.172
The militia movement also emerged because of the 51-day standoff between
federal law enforcement and a religious sect named the Branch Davidians near
Waco.173 On February 28, 1993, an unsuccessful attempt by Bureau of Alcohol
Tobacco Firearms and Explosives (ATF) agents to arrest the sect’s leader, David
Koresh, initiated the events near Waco. He was wanted on suspicion of federal
firearms and explosives violations.174 Four ATF agents and six Branch Davidians
died in a gunfight during the operation.175 Protracted discussions followed
between federal negotiators and Koresh. These failed. On April 19, federal agents
assaulted the Davidian compound, which caught on fire. At least 75 Branch
Davidians perished in the assault.176

168

Ibid., p. 228.
Ibid., pp. 230-231. See also Michael Barkun, “Appropriated Martyrs: The Branch Davidians and the Radical Right,”
Terrorism and Political Violence, vol. 19, no. 1 (2007), p. 120. Hereinafter: Barkun, “Appropriated Martyrs.” See also
Steven M. Chermak, Searching for a Demon: The Media Construction of the Militia Movement, (Boston: Northeastern
University Press, 2002).
170
Stuart A. Wright, Patriots, Politics, and the Oklahoma City Bombing (New York: Cambridge University Press,
2007), pp. 142-148. Hereinafter: Wright, Patriots. Weaver has been described as a survivalist who believed in the
Christian Identity religion. See Barkun “Appropriated Martyrs,” p. 118. He has also been described as holding white
supremacist beliefs and was not a militia member. See Crothers, Rage on the Right, pp. 78-79.
171
Crothers, Rage on the Right, p. 90.
172
Wright, Patriots, pp. 149-152; Crothers, Rage on the Right, pp. 92-97; Barkun, “Appropriated Martyrs,” pp. 120121.
173
Crothers, Rage on the Right, p. 104.
174
Department of Justice, Report to the Deputy Attorney General on the Events at Waco, Texas, October 8, 1993. The
Branch Davidian sect emerged from the Seventh-Day Adventist Church and was formed in 1929. The two severed
official ties with one another in 1934. David Koresh was not a militia member. See Crothers, Rage on the Right, pp.
100-101.
175
Crothers, Rage on the Right, p. 105.
176
Crothers, Rage on the Right, p. 110.
169

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If the incidents involving the Weavers and the Branch Davidians helped form the militia
movement, Timothy McVeigh’s bombing of the Alfred P. Murrah Federal Building in Oklahoma
City on April 19, 1995, helped usher in a temporary decline.177 In the bombing’s aftermath, militia
groups received greater law enforcement scrutiny.178 The bombing claimed 168 lives, and until
9/11 was the largest single act of terrorism on U.S. soil. The militia movement declined after the
bombing.179 Although McVeigh’s bombing cannot fully account for a dip in militia activity, it
affected the movement by causing some groups to temper their rhetoric while others grew more
extreme, and militias became more marginalized.180
Observers have noted that the militia movement has experienced resurgence in the last decade,
likely driven by growing antipathy toward the federal government.181 A few individuals still draw
inspiration from McVeigh. Jerry Drake Varnell was arrested in August 2017 after he allegedly
intended to damage or destroy a bank in downtown Oklahoma City by reportedly attempting to
detonate what he thought was a bomb in a van. But the inert explosive device was based on
materials provided by an undercover FBI agent as part of an investigation that nabbed Varnell,
who allegedly was inspired by the Timothy McVeigh’s 1995 bombing. Varnell purportedly hewed
to militia extremist beliefs and, according to investigators, expressed an interest in founding a
small militia.182
Two widely reported incidents in recent years have attracted militia and other anti-government
extremists.




In 2014, multiple individuals led by Cliven Bundy engaged in an armed standoff
with police officials at Bundy’s ranch in Bunkerville, NV, preventing the
execution of a court order related to a dispute involving the grazing of cattle on
federal lands.183 One individual involved was sentenced to 68 years in prison for
a variety of crimes related to his involvement in the standoff.184
For 41 days in late 2015 and early 2016, Ammon and Ryan Bundy (sons of
Cliven Bundy) led numerous individuals in armed occupation of federal property
at the Malheur National Wildlife Refuge in Oregon. Although the ringleaders of
the broader occupation—including the Bundy brothers—were acquitted in

177

McVeigh was not a militia member, but he interacted with others who were.
Devlin Barett and Eileen Sullivan, “FBI Sees Little Chance of Copycat Militia Plots,” Associated Press, March 31,
2010.
179
Andrew Wolfson, “The Execution: Militias Dwindle Since Oklahoma City Bombing,” USA Today, June 20, 2001.
180
Crothers, Rage on the Right, p. 138, 147.
181
Max Strasser, “Fed Up with the Feds,” Newsweek, May 2, 2014.
182
Eli Watkins and Shimon Prokupecz, “FBI Arrests Man in Oklahoma Bombing Sting,” CNN, August 14, 2017;
United States v. Jerry Drake Varnell, criminal complaint, U.S. District Court, Western District of Oklahoma, August
13, 2017.
183
“Federal Authorities Indict 19 in 2014 Range Standoff in Nevada,” Associated Press, March 4, 2016; Department of
Justice, “Fourteen Additional Defendants Charged for Felony Crimes Related to 2014 Standoff in Nevada,” press
release, March 3, 2016; United States v. Cliven Bundy, et al. superseding indictment, United States District Court,
District of Nevada, March 2, 2016. This standoff is included in this memo’s list of domestic terrorist/extremist
incidents, because the superseding indictment in the federal criminal case related to the standoff describes it as “a
massive armed assault against federal law enforcement officers.”
184
The charges included assault on a federal officer; threatening a federal law enforcement officer; obstruction of the
due administration of justice; interference with interstate commerce by extortion; interstate travel in aid of extortion;
and three counts of use and carry of a firearm in relation to a crime of violence. See Department of Justice, “Phoenix
Man Sentenced to Over 68 Years in Prison for Threat and Assault of Federal Law Enforcement and Other Charges
Related to 2014 Armed Standoff in Bunkerville,” press release, July 26, 2017.
178

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federal court of many of the most serious charges levied against them, a violent
incident occurred during the occupation. Oregon State Police officers fatally shot
LaVoy Finicum. The shooting occurred after Finicum reportedly drove a pickup
truck at high speed toward a police roadblock, reputedly endangering officers
before careening into a nearby snowbank. According to law enforcement
officials, Finicum subsequently left the vehicle, refusing to comply with police
commands, and reached for a gun in his pocket before he was shot to death.185 In
the fallout related to the Malheur National Wildlife Refuge takeover, Cliven
Bundy was arrested on charges tied to the 2014 Bunkerville standoff.
Several other examples highlight how some militia adherents have reportedly engaged in criminal
activity since 9/11.




Purportedly, Curtis Allen, Gavin Wright, and Patrick Eugene Stein conspired to
detonate explosives at an apartment complex in Garden City, KS. Prosecutors
allege Allen, Wright, and Stein hoped to target Somali immigrants living in the
complex.186 The trio was part of a small militia-style group dubbed the Crusaders.
Underscoring the violent viewpoints the trio reputedly held, a larger militia
organization in Kansas reportedly rejected Wright and Stein for membership
because the larger group perceived the duo as too extreme.187
In November 2011, the FBI arrested four retirees, Samuel J. Crump, Ray H.
Adams, Dan Roberts, and Frederick W. Thomas, who allegedly formed a fringe
militia group and planned violent attacks on government officials. The group,
based in northern Georgia, purportedly had ties to an unnamed militia
organization. According to DOJ, the quartet “discussed multiple criminal
activities, ranging from murder; theft; manufacturing and using toxic agents; and
assassinations in an effort to undermine federal and state government and to
advance their interests.”188 Between June and November 2011, Roberts and
Thomas met with an FBI undercover agent to negotiate the purchase of matériel
for the plot: “a silencer for a rifle and conversion parts to make a fully automatic
rifle, as well as explosives.”189 In October, plotters reportedly discussed making
ricin, a deadly poison derived from castor beans.190 In April 2012, Roberts and
Thomas pled guilty to conspiring to obtain an unregistered explosive device and

185

Patrik Jonsson, “After the Bundy Acquittal, Some Surprising Lessons of the Malheur Occupation,” Christian
Science Monitor, October 29, 2016; Hal Bernton, “Jury Acquits Leaders of Malheur Wildlife-Refuge Standoff,” Seattle
Times, October, 27, 2016. A second trial led to additional verdicts, see Department of Justice, “Jury Delivers Verdict in
Second Oregon Standoff Trial,” press release, March 10, 2017. Greg Botelho and Michael Martinez, “Shooting Death
of LaVoy Finicum Justified, Necessary, Prosecutor Says,” CNN, March 8, 2016. In 2017, an FBI agent involved in the
Finicum shooting was federally indicted for his allegedly attempting to cover up his own involvement in the shooting.
See Maxine Bernstein, “LaVoy Finicum Shooting: Indictment of Agent ‘devastating’ for FBI,” The Oregonian, June
29, 2017.
186
Department of Justice, “Three Kansas Men Charged With Plotting a Bombing Attack Targeting the Local Somali
Immigrant Community,” press release, October 14, 2016.
187
Judy L. Thomas, “Kansas Militia Says It Spurned Alleged Terrorists Arrested in Garden City Case,” Kansas City
Star, November 2, 2016.
188
Department of Justice, “North Georgia Men Arrested, Charged in Plots to Purchase Explosives, Silencer and to
Manufacture a Biological Toxin,” press release, November 1, 2011.
189
Ibid.
190
Craig Schneider, “Documents: Men with Castor Beans, Guns Worried about Getting Caught,” Atlanta JournalConstitution, November 6, 2011.

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

silencer.191 Crump and Adams were found guilty of “conspiring to make ricin to
be used as a weapon in January 2014. Also, they were found guilty of one count
each of possessing a biological toxin for use as a weapon.” Adams was acquitted
of “attempting to develop, produce and possess a biological toxin.”192
In June 2012, three individuals were found guilty in Anchorage, AK, of
conspiracy and firearms charges related to a scheme purportedly led by Francis
“Schaeffer” Cox.193 He and his followers allegedly plotted “a potential retaliatory
response to any attempt by law enforcement to arrest Cox, who had an
outstanding bench warrant for not attending a trial over a misdemeanor weapons
charge.”194 They were members of the Alaska Peacemaker’s Militia based in
Fairbanks, AK, and also held sovereign citizen beliefs. The plotters supposedly
codenamed their plan “241 (two for one),” because they reputedly intended to
kill two government officials for every militia member killed in the operation.195

The above activities are not necessarily indicative of trends toward violence in the larger militia
movement, and in one prominent case, DOJ failed to convince the presiding judge of serious
charges revolving around a purported violent plot. In March 2012, a federal judge acquitted
members of a Michigan Militia group known as the Hutaree on charges of seditious conspiracy or
rebellion against the United States and conspiring to use weapons of mass destruction. The judge
also cleared the accused Hutaree members of weapons crimes related to the conspiracies.196
The case garnered headlines in March 2010, when nine Hutaree members were indicted for
allegedly preparing to violently confront U.S. law enforcement.197 Their supposed plotting
included the murder of a local law enforcement officer and an attack on fellow officers who
gathered in Michigan for the funeral procession. According to DOJ, the Hutaree discussed the use
of explosives against the funeral procession.198 Audio recordings by an undercover FBI agent of
reputed Hutaree leader David Brian Stone capture him discussing the New World Order and how,
“it’s time to strike and take our nation back so we will be free of tyranny.... The war will come
191

Department of Justice, “North Georgia Men Plead Guilty to Plot to Purchase Explosives and a Silencer,” press
release, April 10, 2012.
192
Kate Brumback, “Jury Finds 2 Georgia Men Guilty in Ricin Plot,” Associated Press, January 17, 2014.
193
Department of Justice, “Guilty Verdicts in USA v. Cox, Barney, and Vernon,” press release, June 19, 2012.
194
Department of Justice, “Superseding Indictment Returned by Federal Grand Jury Against Fairbanks-Area Men for
Conspiracy to Kill Federal Officers,” press release, January 23, 2012; Sam Friedman, “Details Emerge in Alleged Plot
to Kill Alaska State Troopers, Judge,” Fairbanks Daily News-Miner, March 3, 2011. Cox has also been described as a
sovereign citizen (discussed below). See Sam Friedman, “The Schaeffer Cox File: The Trail of a Young Man,”
Fairbanks Daily News-Miner, April 10, 2011. For a related case see Department of Justice, “Salcha Couple Pleads
Guilty to Conspiracy to Murder Federal Officials,” press release, August 27, 2012; Department of Justice, “Couple
Charged with Conspiracy to Murder Judge and Federal Firearms Crimes, Two Others Indicted for Conspiracy to
Possess Destructive Devices and Illegal Weapons,” press release, March 17, 2011.
195
For examples of other militia adherents involved in crime, see Meghann M. Cuniff, “Health Problems Reduce
Militia Leader’s Sentence,” The Spokesman-Review, August 11, 2011; David Cole, “Militia Member Sentenced on
Federal Firearms and Explosives Charges,” Coeur d’Alene Press, August 9, 2011; Federal Bureau of Investigation,
“Preventing Terrorist Attacks on U.S. Soil: The Case of the Wrong Package Falling into the Right Hands,” April 9,
2004; Scott Gold, Case Yields Chilling Signs of Domestic Terror Plot,” Los Angeles Times, January 7, 2004.
196
Ed White, “Michigan Militia Members Cleared of Conspiracy,” Associated Press, March 27, 2012,
http://abcnews.go.com/US/wireStory/critical-charges-dropped-michigan-militia-16013255?singlePage=
true#.T3MB5kd_lLc. Hereinafter: White, “Michigan Militia.”
197
Department of Justice, “Nine Members of a Militia Group Charged with Seditious Conspiracy and Related
Charges,” press release, March 29, 2010.
198
Ibid.

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whether we are ready or not.”199 According to DOJ, the group had a hit list that included federal
judges, among others.200 However, during the trial an Assistant U.S. Attorney acknowledged that
the Hutaree had not formed a “specific plan” to attack government targets.201 U.S. District Judge
Victoria Roberts stated that, “The court is aware that protected speech and mere words can be
sufficient to show a conspiracy. In this case, however, they do not rise to that level.”202 Three
Hutaree members pled guilty to firearms charges.203

Sovereign Citizen Movement
The FBI defines the sovereign citizen movement as “anti-government,” involving people “who
believe that even though they physically reside in this country, they are separate or ‘sovereign’
from the United States. As a result, they do not accept any government authority, including
courts, taxing entities, motor vehicle departments, or law enforcement.”204 However, simply
holding these views is not a criminal act, and numerous movement adherents solely exercise their
beliefs via constitutionally protected activities.
The ideas behind the movement originated during the 1970s with a group known as the Posse
Comitatus and enjoyed some popularity in extremist circles during the 1980s and 1990s.205 Early
on, the movement featured white supremacist elements, but this has not kept some African
Americans from subscribing to its ideals in recent years.206 In the 1990s, the movement attracted
250,000 followers and was marked by the FBI’s standoff with a group known as the Montana
Freemen that lasted 81 days.207 Estimates from 2011 suggested a membership of 300,000.208
199

Corey Williams and Jeff Karoub, “Prosecutor: Undercover FBI Agent Infiltrated Militia,” Associated Press, March
31, 2010.
200
Dan Harris, Emily Friedman, and Tahman Bradley, “Undercover Agent Key Witness Against Hutaree Militia
Members,” ABC News, April 1, 2010, http://abcnews.go.com/GMA/undercover-agent-credited-hutaree-militia-bust/
story?id=10257584.
201
Robert Snell and Christine Ferretti, “Key Charges Dropped Against Hutaree Militia,” Detroit News, March 28,
2011.
202
White, “Michigan Militia.”
203
See Department of Justice, “Members of the Hutaree Militia Plead Guilty to Weapons Charges,” March 29, 2012;
Matthew Dolan, “Defendant in Michigan Militia Case Changes Plea to Guilty,” press release, December 6, 2011,
http://online.wsj.com/article/SB10001424052970204083204577080630555077796.html?mod=googlenews_wsj. When
the Hutaree suspects were arrested in the case, some militia members in Michigan did not support the group’s alleged
scheming. For example, a member of another militia group in Michigan provided information to authorities regarding
the whereabouts of a fugitive Hutaree militia member. See Kirk Johnson, “Militia Draws Distinctions Between
Groups,” New York Times, March 31, 2010. Also, a militia leader from Michigan has said that the Hutaree case,
“caused a rift in the militia movement about whether this is the

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/crs%3AR44921. Public record. Not legal advice.