UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
LUIGI NICHOLAS MANGIONE,
Defendant.
SOUTHERN DISTRICT OF NEW YORK, ss.:
Original
AUSAS: Dominic A. Gentile,
Jun Xiang, Alexandra Messiter
24 MAG 4375
SEALED COMPLAINT
Violations of
18 U.S.C. §§ 2261A, 2261(b), 924(j), and
924(c)
COUNTY OF OFFENSE:
NEW YORK
GARY W. COBB, being duly sworn, deposes and says that he is a Special Agent with the
Federal Bureau of Investigation, and charges as follows:
COUNT ONE
(Stalking – Travel in Interstate Commerce)
1. From at least in or about November 24, 2024 to in or about December 4, 2024, in
the Southern District of New York and elsewhere, LUIGI NICHOLAS MANGIONE, the
defendant, traveled in interstate commerce with the intent to kill, injure, harass, intimidate, and place
under surveillance with intent to kill, injure, harass, and intimidate another person, and in the
course of, and as a result of, such travel engaged in conduct that placed that person in reasonable
fear of the death of, and serious bodily injury to, that person, and in the course of engaging in such
conduct caused the death of that person, to wit, MANGIONE, traveled from Georgia to New York,
New York for the purpose of stalking and killing Brian Thompson, and while in New York,
MANGIONE stalked and then shot and killed Thompson in the vicinity of West 54th Street and
Sixth Avenue.
(Title 18, United States Code, Sections 2261A(1)(A) and 2261(b)(1).)
COUNT TWO
(Stalking – Use of Interstate Facilities)
2. From at least in or about November 24, 2024 to in or about December 4, 2024, in
the Southern District of New York and elsewhere, LUIGI NICHOLAS MANGIONE, the
defendant, with the intent to kill, injure, harass, intimidate, and place under surveillance with intent
to kill, injure, harass, and intimidate another person, used an electronic communication service and
electronic communication system of interstate commerce, and a facility of interstate or foreign
commerce, to engage in a course of conduct that placed that person in reasonable fear of the death
of and serious bodily injury to that person, and in the course of engaging in such conduct caused
the death of that person, to wit, MANGIONE used a cellphone, interstate wires, interstate