BILLY J. WILLIAMS, OSB #901366

United States Attorney

District of Oregon

ETHAN D. KNIGHT, OSB #99298

GEOFFREY A. BARROW

CRAIG J. GABRIEL, OSB #012571

Assistant United States Attorneys

ethan.knight@usdoj.gov

geoffrey.barrow@usdoj.gov

craig.gabriel@usdoj.gov

1000 SW Third Ave., Suite 600 

Portland, OR 97204-2902

Telephone: (503) 727-1000 

Attorneys for United States of America

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

UNITED STATES OF AMERICA

v.

DYLAN ANDERSON,

Defendant.

3:16-CR-00051-BR-11

GOVERNMENT’S RESPONSE 

IN OPPOSITION TO DEFENDANT 

ANDERSON’S MOTION FOR 

REVIEW OF DETENTION ORDER

The United States of America, by Billy J. Williams, United States Attorney for the 

District of Oregon, and Ethan D. Knight, Geoffrey A. Barrow, and Craig Gabriel, Assistant United 

States Attorneys, provides this response in opposition to Defendant Anderson’s Motion for 

Review of Detention Order. For the reasons outlined below, and as will be presented at the 

review of detention hearing, the government is recommending that defendant Anderson remain in 

custody pending trial, as he is a flight risk and he presents a danger to the community. 

Case 3:16-cr-00051-BR Document 437 Filed 04/20/16 Page 1 of 6
Gov’t’s Resp in Opp to Def Anderson’s Mot for Review of Det Order Page 2

I. Procedural History

Defendant was arrested by the FBI on or about January 27, 2016, at an FBI checkpoint near 

the Malheur National Wildlife Refuge (MNWR). On January 28, 2016, Magistrate Judge Stacie 

Beckerman authorized a complaint charging defendant with Conspiracy to Impede Officers of the 

United States from Discharging their duties through the Use of Force, Intimidation, or Threats in 

violation of Title 18, United States Code, Section 372. That same day, defendant made his initial 

appearance on the complaint in the District of Oregon. He was temporarily detained at his initial 

appearance. 

Defendant appeared before Judge Beckerman for a detention hearing on January 29, 2016. 

Following argument, Judge Beckerman ordered defendant detained as a risk of flight and a danger 

to the community.

On February 3, 2016, a grand jury in the District of Oregon charged defendant with a single 

count of 18 U.S.C. § 372. On March 8, 2016, the grand jury returned a superseding indictment. 

Count One charges defendant with Conspiracy to Impede Officers of the United States from 

Discharging their duties through the Use of Force, Intimidation, or Threats in violation of Title 18, 

United States Code, Section 372. Count Two charges defendant with Possession of Firearms and 

Dangerous Weapons in Federal Facilities in violation of Title 18, United States Code, Section 

930(b) and 2. Defendant is not named in Counts Three, Four or Five. Defendant was arraigned 

on the Superseding Indictment on March 9, 2016.

Defendant has now moved this Court for an Order revoking Judge Beckerman’s January 

29, 2016, Order of Detention. Defendant’s motion is set for a hearing before this Court on 

Wednesday, April 20, 2016, at 10:30 a.m.

Case 3:16-cr-00051-BR Document 437 Filed 04/20/16 Page 2 of 6
Gov’t’s Resp in Opp to Def Anderson’s Mot for Review of Det Order Page 3

II. Argument

Defendant Dylan Anderson was among the first to join the armed occupation at the 

Malheur National Wildlife Refuge. As shown below, on January 3, 2016, the defendant was 

photographed guarding the entrance to the refuge. He was also photographed in and around the 

refuge carrying a rifle. While on the refuge, defendant Dylan Anderson told a reporter, “I didn’t 

come here to shoot, I came here to die.” He further explained that he was inspired to come to the 

Malheur National Wildlife Refuge by Ammon Bundy. The defendant said that his inspiration to 

join the armed occupation was validated by God in the form of a flock of geese. Defendant told 

reporters, “I just knew it was the right thing [to come to Oregon] . . . . I’m willing to die here.”

Case 3:16-cr-00051-BR Document 437 Filed 04/20/16 Page 3 of 6
Gov’t’s Resp in Opp to Def Anderson’s Mot for Review of Det Order Page 4

Defendant Dylan Anderson brought at least two firearms with him from his home in Utah 

to the Malheur National Wildlife Refuge. The assault rifle shown below was purchased by 

defendant Dylan Anderson in 2014. The handgun shown below was purchased by one of Dylan 

Anderson’s family members.

Case 3:16-cr-00051-BR Document 437 Filed 04/20/16 Page 4 of 6
Gov’t’s Resp in Opp to Def Anderson’s Mot for Review of Det Order Page 5

Case 3:16-cr-00051-BR Document 437 Filed 04/20/16 Page 5 of 6
Gov’t’s Resp in Opp to Def Anderson’s Mot for Review of Det Order Page 6

Defendant Dylan Anderson abandoned these firearms before he left the refuge on or about 

January 27, 2016. Defendant was among the last occupiers to leave the refuge. Both of the 

above weapons were recovered by the FBI’s Evidence Response Team after all of the occupiers 

had left the refuge.

The government believes that defendant Dylan Anderson should be detained as both a 

flight risk and as a danger to the community. But in candor to the Court, the government will note 

that defendants similarly situated to defendant Dylan Anderson have now been released pending 

trial in this case.

III. Conclusion

The government recommends that the Court deny defendant Dylan Anderson’s motion for 

pretrial release.

Dated this 20th day of April 2016.

Respectfully submitted,

BILLY J. WILLIAMS

United States Attorney

s/Geoffrey A. Barrow

ETHAN D. KNIGHT, OSB #99298

GEOFFREY A. BARROW

Assistant United States Attorneys

Case 3:16-cr-00051-BR Document 437 Filed 04/20/16 Page 6 of 6