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United States v. Miller

United States Court of Appeals for the Sixth Circuit
767 F.3d 585 (2014)


Facts

The Bergholz Amish community, located in Jefferson County, Ohio, appointed Samuel Mullet as its leader after its establishment in 2001. In 2006, Mullet excommunicated multiple community members. Four of them were the parents of two young men who had married two of Mullet’s daughters, which led to significant strife between the families. For instance, one of the young men married to Mullet’s daughter divorced her and fled. He ultimately won custody of their children, which was devastating to the Bergholz community. Causing further discord, Amish leaders from other communities voted to reverse the Bergholz excommunications due to questionable practices within that compound, which allowed former Bergholz members to relocate to new Amish communities. Starting in September 2011, several members of the Bergholz community (the assailants) (defendants) attacked nine people from other Amish communities by forcibly cutting the men’s beards and the women’s hair. Long beards and hair symbolize religious devotion in the Amish faith. The victims all had some personal connection to Bergholz, including that they played some role in reversing the excommunications and were considered hypocrites by the assailants. Sixteen of the assailants were indicted for violating the Matthew Shepard and James Byrd, Jr. Hate Crimes Prevention Act, which helped protect against hate crimes. At trial, there was no dispute that the attacks occurred or that most of the assailants participated. The question was whether the assailants attacked the victims because of the victims’ religious beliefs. The assailants maintained that the attacks resulted from a combination of interpersonal and family conflicts. The jury was instructed that the element of intent was satisfied if a victim’s religion was a “significant motivating factor” for the attack, even if there were also other reasons. All of the assailants were convicted of at least one count under the act. On appeal, the assailants argued that the term “because of” used in the act requires a showing of but-for causation (i.e., they would not have assaulted the victims but for the victims’ religion).

Rule of Law

Issue

Holding and Reasoning (Sutton, J.)

Dissent (Sargus, J.)

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