United States v. Keith Dwayne Gilbert

Keith Dwayne Gilbert appeals his conviction under 42 U.S.C. § 3631 . Section 3631 prohibits interference with housing rights through force or threat of force. We have jurisdiction under 28 U.S.C. § 1291 , and we affirm.

I

Keith Gilbert was once a member of the Aryan Nations. He left that group to form his own white supremacist hate group. Evidence at Gilbert’s trial showed that he was a racist and a bigot, that he believed White Aryans should not be in contact with any other race, that he believed children born to parents of differing races were not human, and that he embraced some Nazi doctrine. Gilbert told a college newspaper reporter that there were “seventeen niggers” in Kootenai County, the county in which he resided, and that by the time his group was through there wouldn’t be any.

In December of 1980, Gilbert mailed a letter and several posters to Susan Smith. Smith was the founder and an employee of an adoption agency that, among other things, placed minority children with white families. The letter “condemned” Smith’s actions and warned her to “keep [her] human trash off [his] property.” The posters were similar. “The Death of the White Race” poster discusses…