Ole Miss Gun File

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UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF MISSISSIPPI

UNITED STATES OF AMERICA

v.

CRIMINAL NO. 3:l5-MJ-048

KYLER CAMPBELL and

VIRGIL DENNISON

ORDER FOR DISMISS L

Pursuant to Rule 48(a)

of

the Federal Rules of Criminal Procedure and by leave

of

court endorsed hereon, the United States Attorney for the Northern District of Mississippi

hereby dismisses the Criminal Complaint against both defendants.

FELICIA C. ADAMS

ROBERT H. NORMAN

Assistant United States Attorney

Mississippi Bar No. 3880

Leave

of

court is granted for the filing

of

the foregoing dismissal. Previously imposed

conditions

of

pretrial release are likewise dismissed and held for naught.

S.

ALLAN ALEXANDER

UNITED STATES MAGISTRATE JUDGE

DATE

Case: 3:15-mj-00048-SAA Doc #: 12 Filed: 10/28/15 1 of 1 PageID #: 17


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STATE OF MISSISSIPPI

LAFAYETTE COUNTY

AFFIDAVIT

Your affiant, STEPHEN THOMASON,

is

a Special Agent with the Federal Bureau

of Investigation, and I have worked in that capacity for 18 years. I am currently assigned

to the FBI's Jackson Field Division, Oxford Resident Agency. I am currently assigned to

an FBI Counterterrorism squad, which includes the Mississippi Joint Terrorism Task Force

(JTTF). As such, I am charged with enforcing federal law. My primary duty and

assignment obligates me to investigate federal crimes. The information contained in this

affidavit is based on my personal knowledge, my training and experience, and information

supplied to me by other law enforcement officers.

On Friday, October 16, 2015, a "Take Down the Flag" rally was held on the

University of Mississippi campus. Protesters included University

of

Mississippi students

and outside groups. Those outside groups included "Black Lives Matter" and counter

protest groups, including the League of the South and the Ku Klux Klan. The University

Police Department was charged with preserving the peace and in that capacity escorted

members

of

the League

of

the South and the Ku Klux Klan back to their vehicles in an

effort to prevent the confrontation from becoming violent.

Yesterday, October 22,2015, the faculty Senate conducted a vote regarding the flag

issue and once again members

of

the League

of

the South and the Ku Klux Klan returned to

the University campus to protest the flag removal vote. Again, there were protesters and

counter protesters creating the very real possibility of violent confrontation. UPD officers

again escorted protesters to their vehicles in an effort to preserve the peace. Kyler

Campbell and Virgil Dennison were two

ofthe

KKK protesters who were escorted to their

vehicle, a blue GMC pickup truck parked in the vicinity of Sorority Row. UPD officers

immediately noticed that, although the truck was unlocked, there were two shotguns in

plain view on the back floor. Officer Justin Watson asked Mr. Campbell to come to the

front of the truck and asked him what was in the back floorboard. Campbell responded

that there were two shotguns in the truck, one his and the other Mr. Dennison's. Officer

Watson asked

ifhe

could clear the weapons to ensure that they were not loaded, and Mr.

Campbell responded that his truck was an extension ofhis home and the Castle Law was in

effect. Officer Watson asked him again ifhe could clear the weapons to make them safe

and Campbell responded, "No." Officer Watson asked dispatch for a records check and

dispatch responded that Campbell had pending felony charges.

Mr. Campbell and Mr. Dennison were advised of their Miranda rights, stated they

understood their rights and agreed to answer questions. Dennison stated that the pump

Case: 3:15-mj-00048-SAA Doc #: 1-1 Filed: 10/23/15 1 of 2 PageID #: 2


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shotgun was his. Campbell claimed the automatic. Dennison further stated that his

shotgun was loaded. Officers then removed the shotguns from the back floorboard and

determined that the Stevens pump shotgun was in fact loaded. The Winchester automatic

was not. Officers asked Mr. Campbell and Mr. Dennison why they brought shotguns on

campus to a protest. Campbell stated that he keeps his shotgun in the truck all the time,

and Dennison stated he put his shotgun in Campbell's truck that morning, but denied

knowing he was coming to the University. Both men were arrested for illegal possession

of weapons on school property. The arresting officers seized both shotguns and three

poster boards, one of which said, "Keep the Flag," another

of

which said, "Black Lives

Dont Matter," and one of which said,

If

diversity wins we all lose."

Stevens and Winchester are both out of state manufacturers. Accordingly, both

shotguns moved in interstate commerce at some time from the situs

of

their manufacture to

the State of Mississippi. Both firearms meet the statutory definition of a firearm in that

they will expel a projective by means of an explosive or were designed to expel a projective

by means

of

an explosive.

I respectfully request that an arrest warrant issue charging Kyler Campbell and

Virgil Dennison with a violation of 18 U.S.C. 922(q). That statute provides in pertinent

part that

It

shall be unlawful for any individual knowingly to possess a firearm that has

moved in interstate commerce at a place that the individual knows or has reasonable

cause to believe, is a school zone."

Special Agent, FBI

Subscribed and sworn to before me on day

of

October,

"

S. ALLAN ALEXANDER

United States Magistrate Judge

Case: 3:15-mj-00048-SAA Doc #: 1-1 Filed: 10/23/15 2 of 2 PageID #: 3


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AO

91

(Rev. 11111) Criminal Complaint

UNITED STATES DISTRICT COURT

for the

Northern District of Mississippi

United States

of

America

)

v.

)

)

KYLER CAMPBELL and

)

VIRGIL DENNISON

)

)

)

Defondant(s)

CRIMIN L COMPL INT

I,

the

complainant in this case, state that the following is true

to

the best

of

my knowledge and belief.

On or about the date(s)

of

October 2015 in the county of in the

Northern District of Mississippi , the defendant(s) violated:

Code Section

Offense Description

18 U.S.C. 922(q} knowing

possession

of a firearm that

had

previously moved

in

interstate

commerce

at a place that

the defendant

knew or

had reasonable cause

to

believe was a school zone.

This criminal complaint is based

on

these facts:

SEE ATIACHED AFFIDAVIT.

o Continued on the attached sheet.

Complainant's signature

STEPHEN

E.

THOMASON,FBI

Printed name nd title

Sworn to me and signed in my presence.

Date: 2DfS-

City and state:

Oxford,

S. ALLAN ALEXANDER

name nd title


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