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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 DISMISSAL

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.

DATE

S. ALLAN ALEXANDER
UNITED STATES MAGISTRATE JUDGE

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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 ofthe 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

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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 "Itshall 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

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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)

CRIMINAL COMPLAINT
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
District of

Northern

October

2015

Mississippi

in the county of

. . .___ in the

, the defendant(s) violated:

Offense Description

Code Section
18U.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.

Continued on the attached sheet.

Complainant's signature

STEPHEN E. THOMASON,FBI
Printed name and title

Sworn to

Date:

City and state:

me and signed in my presence.

2DfSOxford,

S. ALLAN ALEXANDER
name and title