"Arizona Man Sentenced to Six Years in Prison for Plot Targeting Christian Churches"

From a Justice Department statement issued Nov. 7, but just posted on Westlaw:

Zimnako Salah, 46, of Phoenix, Arizona, was sentenced today in the Eastern District of California to six years in prison in connection with his plot targeting Christian churches.

In March 2025, a jury in Sacramento convicted Salah of strapping a backpack around the toilet of a Christian church in Roseville, with the intent to convey a hoax bomb threat and to obstruct the free exercise of religion of the congregants who worshipped there. The jury's verdict included a special finding that Salah targeted the church because of the religion of the people who worshipped there, making the offense a hate crime.

According to the evidence at trial, from September to November of 2023, Salah traveled to four Christian churches in Arizona, California, and Colorado, wearing black backpacks. At two of those churches, Salah planted those backpacks, placing congregants in fear that they contained bombs. At the other two churches, Salah was confronted by security before he got the chance to plant those backpacks.

While Salah had been making bomb threats by planting backpacks in Christian churches, he had been building a bomb capable of fitting in a backpack. During a search of his storage unit, an FBI Bomb Technician seized items that an FBI Bomb Expert testified at trial served as component parts of an improvised explosive device (IED).

A search of Salah's social media records revealed that he had consumed extremist propaganda online. Specifically, those records showed that Salah had searched for videos of "Infidels dying," and he had watched videos depicting ISIS terrorists murdering people. In a cellphone video taken days before the crimes of conviction, Defendant Salah declared, "America. We are going to destroy it." …

"Salah's seeming ultimate goal to bomb a Christian church would have resulted in many deaths and injuries if his plan had not been thwarted," said U.S. Attorney Eric Grant. "Thanks to the action of church security, local law enforcement, and the FBI, this defendant was stopped before he had a chance to carry out the crimes he sought to commit. Today's sentence is justified by the history and characteristics of this defendant and serves to protect the public from this defendant. And it affirms that people of all religions should be able to worship freely and exercise their First Amendment rights in this country without fear of violence." …

From the government's Sentencing Memorandum:

A cellphone video, dated November 10, 2023—two days before the crimes of conviction in Roseville, California—shows Defendant Salah outside a Christian church in San Francisco, California, with a black backpack. Defendant Salah points to an American flag and says, "Fuck that flag," and "America—we're going to destroy it."

His statements on that video are consistent with statements he made to another witness, A.R., months earlier. When Defendant Salah observed A.R. wearing a hat with the American flag on it, Defendant Salah exclaimed "fuck this country" and "I hate America," elaborating that he was angry with the U.S. military for bombing and killing Iraqis. A cellphone video taken during that period shows an American B52 bomber, with Defendant Salah commenting: "Idiots, what is this you are displaying? All the world got killed by this U.S. Air Force airplane! You must remove it, otherwise I will remove it. There is no God but Allah."

You can see more details in the Criminal Complaint.

Comments

[AmosArch]

I'm sure this is going into the memory hole of the stats Ilya uses to show how illegals or at least those that would have formerly been illegals and leftwingers are so much more tolerant and law abiding.

[Rossami]

What evidence do you have that Salah is an immigrant at all, much less an illegal immigrant? The article and the linked documents all describe him as "of Phoenix, Arizona". In conventional usage, that would imply (though not prove) that he's a citizen.

[mulched]

Not an element of the crime, and they're not going to prove his immigration status at trial, so they're not going to put it in the complaint. They just need to establish jurisdiction. Arizona resident is plenty.

[AmosArch]

He's from Iraq but its a little buried so I'm sure the 'leftwingers only commit one crime per year in the entire nation'
'statistician' that went viral on here and goes viral over social media every few months to own the chuds is going to mark him down as an American.

[not guilty]

IOW you have no clue as to whether his immigration status is unlawful or not, AA?

Or do you simply not care about the truth or falsity of your comments?

[Roger S]

He is from Iraq. He is not an American. What more do you need to know?

[Incunabulum]

We don't care if he's here legally or not - he's an Iraqi, *NOT* an 'Arizona-man' nor is he 'from Arizona'.

[gormadoc]

"that would imply"
At least in my area, that phrasing just means that's where they currently live. It gets used for citizens, refugees, and legal or illegal residents. The only people not covered are college students or homeless traveling through.

[David Nieporent]

I googled the guy; it says that he came from Iraq like 20 years ago, legally. So he may be a citizen (that wasn't clear), but he's also an immigrant.

[Incunabulum]

Yeah, the same way they describe Abrego as 'of Maryland'.

>In conventional usage, that would imply (though not prove) that he's a citizen.

That's the point of doing it that way. If he were born here they'd say that outright to 'own the chuds'. That they don't is a strong indication that he's not.

[Old Smokin' Egg]

The press release noted that the jury found Salah's to be a hate crime, and places much emphasis on his action as infringing people's right to worship.

Does this imply that the crime wouldn't have been as bad, and that the sentence should've been lighter, if Salah had targeted, say, movie theaters or nightclubs? Or suppose that his motive had been purely mercenary, with no particular animus toward Christians: say, he'd wanted to destroy one of the churches so that he could acquire the property at a reduced price and build something of his own there?

The concept of "hate crime" is a bad idea, whether it be applied by the right or by the left. Criminal convictions and sentences should be based on the actions or attempted actions of the perpetrator, regardless of their motives, or what prosecutors can represent as their motives.

[David Nieporent]

Criminal convictions and sentences should be based on the actions or attempted actions of the perpetrator, regardless of their motives, or what prosecutors can represent as their motives.

So if someone approaches me on the sidewalk with a knife drawn and I shoot him, that should garner me the same punishment as if someone cuts me off in line at CVS and I shoot him? After all, my action — shooting the guy — is the same in each case; the difference is my motive (self-defense vs. annoyance).

Hate crimes — at least if reasonably defined; a particular law may be written badly or misapplied, obviously — have more victims; that's why they're punished more. If someone assaults a Jewish guy because he thinks the Jewish guy stole his car, the victim is the guy who got assaulted. If someone goes out and assaulted a random Jewish guy for being Jewish, the victim is the guy who got punched and the Jewish community in general, who now are in fear that they will be assaulted simply for existing.

[Jack Jordan]

David, the problem with your approach is that the "hate crime" that is being punished is, in fact, mere "hate speech." A criminal penalty is being imposed for mere speech that revealed a motive that some people hate. That's not consistent with our Constitution or the SCOTUS precedent construing and securing our freedom of speech and press.

Of course, some motives matter. As SCOTUS emphasized in District of Columbia v. Heller, defense and preservation are extremely powerful motives, and such motives are among the most legitimate. As our first words as a nation (the first words of our Constitution) emphasized, "We the People" did "ordain and establish" our "Constitution," in part, to "provide for the common defence." However, our Constitution also was amended very promptly to cause the First Amendment to emphasize that government employees are prohibited from "abridging the freedom of speech, or of the press."

[Bored Lawyer]

"David, the problem with your approach is that the "hate crime" that is being punished is, in fact, mere "hate speech." A criminal penalty is being imposed for mere speech that revealed a motive that some people hate."

No it isn't. It's being impose for a criminal act. It's just that the speech evidences a bad motive, or, more accurately, a worse motive. See my below comment.

[Jack Jordan]

Bored, yes, the speech clearly is being punished separately from the violent act that the law made criminal. That's the whole point of increasing the amount of prison time for so-called hate speech associated with a violent crime.

[Jack Jordan]

Bored Lawyer, look again at the words attributed to Salah in the original piece. The government argued Salah's words justified a hate crime sentence enhancement.

Contrast Salah's words with strikingly similar words that SCOTUS nearly unanimously decided to protect in 2011 in Snyder v. Phelps (in an opinion that Chief Justice Roberts chose to author). In Snyder, SCOTUS justices emphasized the freedom of speech in America. More particularly, they emphasized the freedom to use even a particular backdrop and even to use particularly hateful messages about Americans who had been killed in the service of this nation. Picketers targeted funerals (and the friends and family) of servicemembers who had been killed in combat. SCOTUS reported that, according to one source, “nearly 600 funerals” had been “picketed.” So not only were hundreds of funerals and families picketed, but SCOTUS justices somewhat immortalized and significantly elevated what picketers said and did by protecting it by, first, granting the petition, and, second, writing a strong, detailed decision.

The signs that SCOTUS justices went out of their way to protect included, “Thank God for Dead Soldiers,” “God Hates the USA/Thank God for 9/11,” “America is Doomed,” “Don’t Pray for the USA,” “Thank God for IEDs” (improvised bombs used to kill servicemembers), “Pope in Hell,” “Priests Rape Boys,” “God Hates Fags,” “God Hates You,” “Fag Troops,” “Semper Fi Fags,” “God Hates Fags,” “Maryland Taliban,” “Fags Doom Nations,” “Not Blessed Just Cursed,” “You’re Going to Hell.”

Some of the principles in Snyder v. Phelps also were reiterated in 303 Creative LLC v. Elenis in 2023, which emphasized the following:

“The First Amendment” means “all persons are free to think and speak as they wish, not as the government demands.” It secures the “freedom to think as you will” and “speak as you think.” It “extends to all persons engaged in expressive conduct, including those who seek profit.” Its “protections belong to all, including” speakers “whose motives” someone considers “misinformed or offensive.” It “protects” each person's “right to speak his mind regardless of whether the government considers his speech sensible” or “misguided,” even if it causes someone “anguish” or “incalculable grief.”

“All manner of speech” enjoys “First Amendment’s protections.” “A commitment to speech for only some messages and some persons is no commitment at all.”

“The freedom of thought and speech” is “indispensable to the discovery and spread of political truth.” “[A]llowing all views to flourish” is necessary to “test and improve our own thinking” as “individuals and as a Nation,” so it is a “fixed star in our constitutional constellation” that “government may not interfere” with the “marketplace of ideas.”

[Bored Lawyer]

So if someone approaches me on the sidewalk with a knife drawn and I shoot him, that should garner me the same punishment as if someone cuts me off in line at CVS and I shoot him?

Bad analogy. That scenario raises self-defense or justification. Hate crime is not an issue there.

Better illustration: A takes a baseball bat and beats up B, breaking a number of his bones, and sending him to the hospital. Aggravated assault (or whatever they call it in that jurisdiction.) A might have three possible motives:

(1) B made advances on A's girlfriend, and A got mad.
(2) A was in the process of robbing B, B resisted in giving A the money, so A retaliated by beating him up.;
(3) A hates blacks, B is black, and A beat him up as part of a racist assault.

Hate crime laws mean that while the assault is certainly punishable regardless of motive, motive (3) should be punished more harshly. It's debatable whether that's valid, but at least understand what's involved.

[MickeyFitz]

“Maryland man” lived in Maryland, was not born there, is not a citizen.

[David Nieporent]

Thank you for sharing that hot take.

[Incunabulum]

Let's bring more of these guys in.