The Volokh Conspiracy
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"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.
