A white supremacist who deliberately plowed his Jeep into a black teenager was sentenced last week to at least 28 years in prison for what is believed to be Oregon’s first hate crime murder conviction in more than three decades. He could have faced as much as 20 additional years in prison if not for an unusual quirk in Oregon law, which imposes softer penalties on anyone who commits a hate crime alone rather than with an accomplice.
The man, Russell Courtier, 40, was convicted of killing Larnell Bruce Jr., 19, in August 2016. Prosecutors said Courtier had joined a white supremacist gang while serving a prior prison sentence, and had scuffled with Bruce before Courtier’s girlfriend urged him to run down the teenager.
Courtier was charged with murder and hit-and-run driving. But when prosecutors tried to add a hate crime charge, the court would only allow him to be charged with a misdemeanor hate crime, rather than a felony. A judge ruled that there was not enough evidence that the girlfriend shared the same beliefs, so she would not be considered an accomplice to the hate crime.
It was similar to the case of Jeremy Joseph Christian, who was accused of stabbing three people, two fatally, aboard a Portland, Oregon, commuter train in May 2017 while screaming anti-Muslim insults. Along with murder, assault and weapons charges, prosecutors added hate crimes charges, but they were misdemeanors, not felonies, because he acted alone. He has pleaded not guilty.
The two high-profile cases have brought attention to efforts to change Oregon’s hate crimes law, which was enacted in 1981 in response to a rise in organized skinhead attacks that often involved more than one assailant.
“This creates a peculiar scenario where two defendants spraying racist graffiti on a wall might reasonably expect to be punished more harshly than one individual who physically attacks someone because of the color of their skin,” said Ellen Rosenblum, Oregon’s attorney general, in testimony last month before the state’s Senate Judiciary Committee.
In 2005, a white supremacist accused of desecrating a Jewish cemetery in Portland with swastikas faced 10 years in prison because he was joined by a co-conspirator, allowing prosecutors to charge him with a felony hate crime, although he was only sentenced to a year.
Rosenblumformed a task force last year to update the hate crimes law, and a bill that would accomplish that is working its way through the state Senate. The current legislative term ends June 30.
Brian Levin, director of the Center for the Study of Hate and Extremism at California State University, San Bernardino, said he was not aware of any other state with a similarly worded hate crimes law. But he said states across the country are re-examining their statutes as an increase in hate crimes is reported nationwide.
“What we’re seeing now, in particular because this is a time that there is an issue with federal enforcement of states’ civil rights laws, is a renewed effort across the United States to bring some of the antiquated hate crimes laws up to modern times,” Levin said.
The number of hate crimes reported in Oregon increased 40 percent from 2016 to 2017, FBI data showed, although half of the 2017 cases were in Eugene, a city of 170,000 that has focused on improving the reporting of hate crimes.
Levin said the Oregon law mirrored the wording of the earliest criminal civil rights laws, which were passed right after the Civil War, when racial terrorism was being committed by Klansmen and local authorities.
“It reflects a bit of a bygone era,” Levin said, “when hate violence was thought to be orchestrated by organized groups.”
Courtier was convicted of killing Bruce after a fistfight in August 2016 outside a convenience store in a Portland suburb. Prosecutors said he was a member of a white supremacist prison gang called the European Kindred. It’s unclear what started the altercation, although prosecutors noted that Courtier was wearing a hat with the European Kindred’s symbol, which was also tattooed on one of his legs.
Authorities said that Courtier’s girlfriend, Colleen Hunt, urged him to drive into Bruce after the two men scuffled. Witnesses testified that they heard her cry out: “Run him over!” and “Get him, baby!”
Hunt pleaded guilty to first-degree manslaughter and was sentenced to 10 years in prison. Courtier was given a life sentence for his murder and hit-and-run conviction but will be eligible for parole in 28 years. (He must also serve four years for a conviction for an attack in a bar in 2015.)
It is believed to be Oregon’s first hate crime murder conviction since skinheads killed an immigrant from Ethiopia with a baseball bat in 1988.
A felony conviction on first-degree intimidation, which is the state’s hate crimes charge, might have given Courtier an additional 20 years in prison, according to Oregon’s sentencing guidelines.
Prosecutors indicted him on charges of intimidation in the first degree and the second degree in Bruce’s killing. But a judge found that they had sufficient evidence only for the second-degree charge, a misdemeanor. Misdemeanor convictions in Oregon carry a maximum sentence of one year in prison.
“If murder isn’t a first-degree hate crime, then that’s part of the law needing reform,” said Randy Blazak, who leads the Oregon Coalition Against Hate Crime and has spent the last 30 years studying hate groups in a state that is 87 percent white.
After Courtier was sentenced last week, Larnell Bruce Sr. approached the father of his son’s killer to express remorse for how the crime had affected both of their families, and the two men shook hands.
“Both of our families have suffered,” Bruce said. “We both lost our sons to hate.”