On June 21, 1995, the Macedonia Baptist Church in Bloomville, South Carolina burned to the ground. In a suit filed August 22, 1996 against the Christian Knights of the Ku Klux Klan-Invisible Empire and four of its members who were indicted for their involvement in the church fire, the church alleges that the fire was racially-motivated and designed to intimidate the Church's congregation, disrupt its activities, and discourage it from holding property in the area.

STATE OF SOUTH CAROLINA

COUNTY OF CLARENDON



IN THE COURT OF COMMON PLEAS

FOR THE THIRD JUDICIAL CIRCUIT





MACEDONIA BAPTIST CHURCH,

an unincorporated association;



Plaintiff,



v.



CHRISTIAN KNIGHTS OF THE KU

KLUX KLAN-INVISIBLE EMPIRE,

INC., a North Carolina corporation;

CHRISTIAN KNIGHTS OF THE KU

KLUX KLAN-INVISIBLE EMPIRE,

an unincorporated South Carolina

association; ARTHUR A. HALEY;

HUBERT "HERBERT" L. ROWELL;

TIMOTHY A. WELCH; and

GARY C. COX;



Defendants.





CIVIL ACTION NO. 96-CP-14-217



AMENDED COMPLAINT

Jury Trial Demanded





Nature of the Action



1. This is a civil action brought by the Macedonia Baptist

Church. The Church's place of religious worship was

destroyed by a fire that was authorized by an officer of

the Christian Knights of the Ku Klux Klan and set by its

members on June 21, 1995. The Church alleges that the fire

was racially-motivated and was designed to intimidate the

Church's congregation, disrupt its activities, and

discourage it from holding property in the area. The Church

seeks compensatory and punitive damages pursuant to South

Carolina's common law governing trespass.





Parties



2. The Macedonia Baptist Church ("Church") is an

unincorporated association. All the members of the Church

are African-Americans. Prior to being destroyed by the

defendants, the Church's place of worship was located on

property in the Bloomville area of Clarendon County. The

Church is the owner and possessor of the property.



3. The Christian Knights of the Ku Klux Klan Invisible

Empire, Inc. ("Christian Knights") is a North Carolina

corporation conducting business in South Carolina.



4. The Christian Knights of the Ku Klux Klan -- Invisible

Empire ("Christian Knights") is an unincorporated

association conducting business in South Carolina. The

association is the South Carolina chapter and an agent of

Christian Knights of the Ku Klux Klan Invisible Empire,

Inc.



5. Arthur Haley is an adult citizen and resident of

Clarendon County. He has been indicted by federal

authorities for his involvement in the Church fire. At the

time of the fire, Haley was an officer and agent of the

Christian Knights.



6. Hubert "Herbert" Rowell is an adult citizen and resident

of Clarendon County. He has been indicted by federal

authorities for his involvement in the Church fire. At the

time of the fire, Rowell was a member and agent of the

Christian Knights.



7. Timothy Welch is an adult citizen and resident of

Clarendon County. He has pled guilty to federal criminal

charges for his involvement in the Church fire. At the time

of the fire, Welch was a member and agent of the Christian

Knights.



8. Gary Cox is an adult citizen and resident of Clarendon

County. He has pled guilty to federal criminal charges for

his involvement in the Church fire. At the time of the

fire, Cox was a member and agent of the Christian Knights.





Jurisdiction and Venue



9. The Court has jurisdiction of this action pursuant to

S.C. Const. art. V, Sec. 11.



10. Venue is proper pursuant to S.C. Code Ann. Sec.

15-7-10(1). This action involves injury to real property

located in Clarendon County.





Statement of Facts



11. The Christian Knights of the Ku Klux Klan was founded

by Virgil Griffin in Mt. Holly, North Carolina, in 1985. As

national leader of the organization, Griffin holds the

title of "Imperial Wizard." The Christian Knights have

chapters in Kentucky, Tennessee, North Carolina, and South

Carolina. Horace King is the "Grand Dragon" or leader of

the South Carolina chapter.



12. The Christian Knights are dedicated to the supremacy of

the white race and advocate the separation of white people

from minority groups. Membership in the organization is

limited to white persons of non-Jewish ancestry.



13. Upon information and belief, the Christian Knights

encourage their members to commit acts of violence and

intimidation against African-Americans to promote the

organization's white supremacist goals.



14. Upon information and belief, the Christian Knights

encourage their members to arm themselves with firearms in

preparation for a race war between blacks and whites.

Defendants Haley and Rowell have been indicted on federal

charges for illegal possession of firearms.



15. One of the tenets of the Christian Knights provides

that "a church that is not grounded on the principles of

morality and justice is a mockery to God and to man." Upon

information and belief, the Christian Knights instructs its

members that churches with predominantly black

congregations promote the interests of black persons to the

detriment of white persons.



16. Upon information and belief, on or about June 21, 1995:



a. defendants Haley, Rowell, Welch, and Cox met at Haley's

residence to discuss burning a church attended by black

parishioners. Haley selected the Macedonia Baptist Church

to be burned.



b. Haley, Rowell, Welch, and Cox willfully conspired and

agreed to injure and intimidate the members of the

Macedonia Baptist Church by setting fire to the Church's

place of worship in Clarendon County.



c. Haley, Rowell, Welch, and Cox agreed that Welch and Cox

would travel to the Church and set it afire.



d. Haley provided flammable liquids from a shed behind his

residence to use as accelerants in burning the Church.



e. Rowell mixed the flammable liquids in a plastic jug and

instructed Welch and Cox how to use the mixture to set the

Church afire.



f. Welch and Cox drove to the Church and forcibly entered

it through a locked side door.



g. Cox poured the flammable mixture on the Church's floor

and Welch ignited the mixture, setting the church afire.

The Church's building was completely destroyed by the fire.



17. Welch and Cox have pled guilty to setting the fire and

are awaiting federal sentencing. Haley and Rowell have been

indicted on federal charges for their involvement in the

fire.



18. The destruction of the plaintiff's Church was

undertaken pursuant to the Christian Knights' practice of

promoting their white supremacist goals through violent

means.



a. Haley, as officer and agent of the Christian Knights,

authorized, aided, and abetted the burning of the Church.

Haley, Rowell, Welch, and Cox, as members and agents of the

Christian Knights, aided and abetted each other in burning

the Church.



b. In the weeks preceding the fire, Haley, Rowell, Welch,

and Cox had attended several Klan meetings and rallies. On

at least one of those occasions, a speaker made disparaging

and inflammatory statements about black churches.



c. Less than a month before the fire, a Klan poster was

tacked to the Church's door. The poster was marked with a

skull and cross-bones and a picture of a hooded Klansman.

Another Klan poster was placed across the street from the

Church on a roadside stake.



Upon information and belief:



d. on or about June 20, 1995, hours before they destroyed

the plaintiff's church, Welch and Cox set fire to the Mount

Zion African Methodist Episcopal (AME) Church in

Greeleyville, South Carolina.



e. on or about March 2, 1995, Haley, Rowell, and other

persons conspired to and set fire to the automobile of

Manuel Leroy Thompson, a black man.



f. on or about February 22,1995, Haley, Rowell, and a third

person conspired to and set fire to a migrant camp, located

off Cecil Road in the Bloomville area of Clarendon County,

that was used by Latino farm workers.



g. on or about October 17,1994, Rowell set fire to a

structure used by Manuel Leroy Thompson, a black man, at

the Clarendon County Service Center (a.k.a. Recycling

Center).



h. on or about October 12,1992, Rowell and other persons

set fire to a migrant camp, located off Liberty Church Road

in the Bloomville area of Clarendon County, that was used

by Latino farm workers.





Cause of Action -- Trespass



19. The defendants' willful entrance upon the Church's

property and their intentional destruction of the Church's

place of worship interfered with the plaintiff's right of

peaceful possession and quiet enjoyment of its property.





PRAYER FOR RELIEF



WHEREFORE, plaintiff prays that this Honorable Court and

the jury award the plaintiff:



(1) compensatory damages for the destruction of its

property;



(2) punitive damages to punish the defendants for their

intentional and malicious acts and to deter others from

engaging in such acts; and



(3) any other relief that the Court deems necessary and

just.



Respectfully submitted,



/s/

Morris S. Dees

J. Richard Cohen

Marcia K. Bull

400 Washington Avenue

Montgomery, AL 36104

(334) 264-0286



/s/

Tom Turnipseed

Peter Tepley

1337 Assembly Street

Columbia, SC 29201

(803) 252-9000



ATTORNEYS FOR PLAINTIFF







CERTIFICATE OF SERVICE



I hereby certify that I have served a true and correct copy

of plaintiff's Amended Complaint by first-class mail,

postage prepaid, on the 21st of August, 1996, on the

persons listed below:



Wm. Gary White, III

2009 Lincoln Street

Columbia, South Carolina 29201-2003



Timothy Welch

Berkeley County Jail

300 California Avenue

Moncks Corner, SC 29461



Gary Cox

Berkeley County Jail

300 California Avenue

Moncks Corner, SC 29461



/s/

Morris S. Dees

J. Richard Cohen

Marcia K. Bull

400 Washington  Avenue

Montgomery, AL 36104

(334)  264 0286



/s/

Tom Turnipseed

Peter Tepley

1337 Assembly Street

Columbia, SC 29201

(803) 252-9000



ATTORNEYS FOR PLAINTIFF