Springfield, OH – Today, Guerline Jozef, the executive director of the Haitian Bridge Alliance, a national non-profit organization, filed a factual supplement to the criminal charges against Donald Trump and JD Vance over their harm to and lies about Springfield.

The supplemental affidavit adds the following information:

• Citing a New York Times story, the affidavit presents the harm to a local businessperson who spoke up in support of his Haitian workers and faced death threats and threats to his business deemed credible by law enforcement. Miriam Jordan, An Ohio Businessman Faces Death Threats for Praising His Haitian Workers, N.Y. Times (Sept. 30, 2024), https://www.nytimes.com/2024/09/30/us/springfield-ohio-haitians-threats.html (cataloguing much of the continuing threats in the Springfield community, especially those to residents who support their Haitian neighbors).
  
  
• Since Trump’s September 10–debate lies, hate groups have converged on Springfield, emboldened by Trump’s and Vance’s legitimizing of anti-Black sentiment, with the intent of terrorizing Haitians immigrants and their supporters.
  
  
• Hate groups including neo-Nazis, the Ku Klux Klan, and the "Proud Boys" have converged on Springfield as a result of Trump and Vance's conduct, posing a threat to the community. Sydney Dawes, Hate groups converge on Springfield after false claims about Haitian immigrants, Springfield News-Sun (Oct. 1, 2024), https://www.springfieldnewssun.com/local/hate-groups-converge-on-springfield-following-false-claims-about-haitian-immigrants/R6BSUOAMGZDNZNSV4PUTBDPOSY/ (documenting the various hate groups that have been active in Springfield since Trump and Vance began spreading their lies); @nlanard, X (Sept. 14, 2024, 4:02 AM), https://x.com/nlanard/status/1835046358488666458 (directing to the X post pictured above); Odette Yousef, In parroting a lie about migrants in Ohio, Trump excited extremists, Nat’l Pub. Radio (Sept. 24, 2024), https://www.npr.org/2024/09/24/nx-s1-5118438/neo-nazi-haitian-springfield-trump-debate (documenting the various hate groups, including the Proud Boys, active in Springfield since Trump and Vance began spreading their lies.)
  
  
• Ohio Governor Mike DeWine has expressed frustration about the futility of appealing to Trump and Vance to change their conduct, saying in a September 30 interview “[i]t’s clear nothing I would say would alter” their conduct. He noted Trump’s misconduct during the debate: “I just started shaking my head... And then he kept on it!” Governor DeWine also said of the comments Trump and Vance made, “their comments are just hurtful, they’re hurtful to a lot of people . . .” “To say that these people are illegal is just not right[;] you can’t make up stuff like that,” he also said. As JD Vance, his fellow Republican and Senator from Ohio continued to insist that his lie about eating pets was true and to falsely call the Haitians “illegal aliens,” DeWine grew “just more infuriated.” “Yeah, after a while, because it got cumulative, and then you keep thinking, “Well, they’re going to stop this,” he said. “Well, they didn’t stop this, they just keep going.” The governor had to send in state troopers to help Springfield, an enormous economic cost. Jonathan Martin, ‘Just Not Right’: A GOP Governor Confronts Trump’s Lies, Politico (Sept. 30, 2024), https://www.politico.com/news/magazine/2024/09/30/dewine-ohio-gop-governor-confronts-trump-lies-00181595 (interviewing Governor DeWine and containing the quotes referenced above).
  
  
• During the October 1, 2024 vice-presidential debate hosted by CBS News, JD Vance again falsely insisted that Haitians in Springfield are there illegally when he knows they are there with the permission of the U.S. government under legal status, using legal procedures. For political gain and recklessly disregarding the consequences for Haitian immigrants and Springfield as a whole, he claimed that Vice President Harris had waved a “wand” to allow the immigrants in, when he knows she had nothing personally to do with it. The CBS News moderators had to fact-check Vance. Just like his earlier admission to Dana Bash that he and Trump have to “create stories” about Haitians for media attention, Vance admitted on stage that he was lying when he protested, “The rules were that you guys weren’t going to fact check!”

The supplemental affidavit is available here.

The complete September 30 amended criminal charges and bench memorandum accompanying it are available here.

They include criminal charges under Ohio and Springfield law of inducing panic, making false alarms, disrupting public service, and aggravated menacing, along with complicity. The charges address Trump's and Vance's misconduct directed at Springfield, Ohio's Haitian population resulting in harm to that community and the Springfield as a whole. The bench memo explains why, under Ohio criminal law interpreting the First Amendment, Trump and Vance have no criminal defense. And the bench memo also explains that the court must issue arrest warrants upon a finding of probable cause, a low legal standard.

Subodh Chandra, The Haitian Bridge Alliance's lead counsel, said, "Not only did Vance lie again during the debate about legal Haitian immigrants in Springfield, by protesting fact checking, he admitted he was lying. He knows the harm he's inflicting and doesn't care. That's criminal."

The case is captioned In re: Criminal Charges Against Donald J. Trump and James David (“JD”) Vance, Clark County Municipal Court Case No. Matter No. 24SPM100. The case has been assigned to the entire municipal court “en banc.”

The Haitian Bridge Alliance and Ms. Jozef are represented by Chandra Law's Subodh Chandra, Alexandra Lavelle, Courtney Bow, and Ethan Dawson. They are also represented by Nicole Phillips, legal director, and Erik Crew, staff attorney, of the Haitian Bridge Alliance.

Led by former federal prosecutor Subodh Chandra, Chandra Law is experienced obtaining justice for crime victims, including initiating charges under R.C. 2935.09. The firm also helped pioneer work in holding individuals and companies accountable for civil liability for criminal acts, securing the two leading Supreme Court of Ohio decisions favorable to crime victims on the topic.

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