Native American Artifact Theft
Native American Artifact Theft
FILED
DEC 1 ~ 2016
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF MISSISSIPPI
INDICTMENT
COUNT ONE
District of Mississippi and elsewhere, MATTHEW GLEN ARNOLD, JACKIE DALE ARNOLD,
MELINDA JEAN CHAFFIN, CHRIS HOLLEY, TYLER W. WILEMON, SANDRA ARNOLD, and
SAMUEL LEE HOWELL, defendants, did knowingly and willfully conspire and agree together and
with each other and with other individuals both known and unknown to the Grand Jury, to commit
(1) knowingly and unlawfully excavating, removing, damaging, and otherwise altering
and defacing archeological resources located on designated historic public lands without having a
permit to do so, wherein the cost of restoration and repair plus the commercial value ofthe resources
is greater than $500.00, in violation of Title 16, United States Code, Section 470ee; and
(2) willfully injuring and conunitting depredation against property ofthe United States, or
any department or agency thereof, wherein the damage inflicted by the defendants exceeded the sum
of $1000.00, in that the defendants probed, dug, and caused irreparable inj ury to a Native American
Case: 1:16-cr-00118-DMB-DAS Doc #: 1 Filed: 12/14/16 2 of 9 PageID #: 2
sacred mound located on United States Corps of Engineer property in Tishomingo County,
Mississippi, adjacent to the Tennessee-Tombigbee Waterway, in violation of Title 18, United States
During and in furtherance of the conspiracy and to effect the objects of the conspiracy, at
least one of the co-conspirators committed at least one of the following overt acts:
WILEMON, defendants, excavated and removed Native American artifacts from a Native American
sacred mound located on United States Corps of Engineer property in Tishomingo County,
ARNOLD, MELINDA JEAN CHAFFIN, SANDRA ARNOLD, and SAMUEL LEE HOWELL,
defendants, excavated and removed Native American artifacts from a Native American sacred
mound located on United States Corps of Engineer property in Tishomingo County, Mississippi,
ARNOLD, and CHRlS HOLLEY, defendants, excavated and removed Native American artifacts
from a Native American sacred mound located on United States Corps of Engineer property in
(d) On or about November 29, 2014, MATTHEW GLEN ARNOLD, MELINDA JEAN
CHAFFIN, and SAMUEL LEE HOWELL, defendants, excavated and removed Native American
artifacts from a Native American sacred mound located on United States Corps ofEngineer property
Waterway.
Tombigbee Waterway.
COUNT TWO
District of Mississippi,
and abetted by
without having a permit to do so, to do the same, wherein the cost of ",,,,,"'AN.T.
repair plus the commercial value of resources is greater than $500.00, in violation
United States, or any department or agency rnt>,"Ar,r wherein the damage inflicted the
defendants exceeded sum of$l 000.00, the defendant pro bed, caused M"pr""-,,
SAMUEL HOWELL, defendants, aided and abetted by other and others known
unknown to the Grand Jury, did knowingly and unlawfully excavate, remove, damage, otherwise
and deface archaeological resources lOcare:o on designated historic public lands without
a permit to do so, and attempt to do same, the cost restoration repair the
Section 470ee(a).
COUNT FIVE
SAMUEL LEE HOWELL, defendants, aided and abetted each other and others known and
unknown to Grand did willfully injure and depredation against ",,.r, ...,,,,.,.., of
exc:eeilea the sum of$l 000_00, that the defendant probed, dug, and caused irreparable injury to a
COUNT SIX
remove, damage, and otherwise and deface archaeological resources located on designated
historic public lands without having a permit to do so, and ~"""U'I-' to do same, wherein cost
other others known and unknown to Grand Jury, did willfully and commit depredation
inflicted by the defendants exceeded sum of $1000.00, that the """'L"'''''''''''< probed, and
abetted by other and known and unknown to Grand Jury, did knowingly and
Case: 1:16-cr-00118-DMB-DAS Doc #: 1 Filed: 12/14/16 6 of 9 PageID #: 6
unlawfully remove, """,.'H".F."', and (un"" .... 'll UV... <o."',", archaeological resources
located on designated historic public lands without having a permit to do so, and attempt to do the
same, wherein cost of restoration and repair plus the commercial value of the resources is greater
ARNOLD, MELINDA JEAN CHAFFIN, and SAMUEL LEE HOWELL, defendants, aided and
wherein the damage inflicted the defendants exceeded the sum of$l 000.00, in that the defendant
probed, dug, caused irreparable to a American sacred mound ..1 ...'<."...' .... on United
ARNOLD and MELINDA defendants, aided and abetted each other and others
known and unknown to the Grand did knowingly and unlawfully excavate, remove, u ......u<O.J;.'"',
without having a permit to do so, attempt to the same, wherein the cost of restoration and
repair the commercial value of the resources is greater than $500.00, in violation of Title 1
known and unknown to the Grand Jury, did willfully injure and commit depredation
defendants the sum of$1 000.00, in that the "'",,",',",Uy,", probed, and \"au~c;u irreparable
injury to a Native American sacred mound located on United States Corps property in
On or about January 17, 15, in the Northern District of Mississippi, MATTHEW GLEN
other and others known and unknown to the Grand Jury, did knowingly and unlawfully
designated historic public without having a permit to do so, and attempt to do same,
wherein the cost of restoration and repair plus the commercial value of the resources is greater than
each other and others known and unknown to Grand Jury, did willfully injure and commit
depredation ~""+''''J' property of the United States, or any rlAr.",rl,,,,, or ~h"'''Ar'''' wherein the
inflicted by the defendants exceeded the sum of$1 000.00, in that defendant probed, dug,
Case: 1:16-cr-00118-DMB-DAS Doc #: 1 Filed: 12/14/16 8 of 9 PageID #: 8
caused irreparable injury to a Native American sacred mound V\VCl"LI;,U on United Corps of
United Code, Section 4 70gg(b) and Title United States Code, ,",,,,,.U,"1>1 1(c).
Upon conviction of one or more ofthe offenses in violation 16 U.S.C. 470ee set forth in
WILEMON, SANDRA ARNOLD, and SAMUEL LEE HOWELL shall forfeit to States
removed from the land by the defendants or other co-conspirators in violation of the aforesaid
statutes and any devices, and things possessed or used violation of 16 U.S.c.
defendant(s):
(e) been commingled other property which cannot divided without difficulty;
Case: 1:16-cr-00118-DMB-DAS Doc #: 1 Filed: 12/14/16 9 of 9 PageID #: 9
the United States of America shall be entitled to forfeiture of substitute property pursuant to
A TRUE BILL
NOTICE OF PENALTIES
Count One
Except in the case of a second or subsequent conviction under 16 U.S.C. 470ee, in which case
Address Booneville, MS
DOB 1983 SS# xxx-xx-0793 Sex M Race W Nationality
---- - -- -- - ----- - - - - -
Represented by: _ _ _ ____ _____ ____ _ __ _ _ _ _ __ __ _ _ _ __ _
Location Status:
Pretrial Release [ZJv es []No In Custody DYes [{]No
Federal State - - - - Date of Arrest
- - - - -- - -- - - - -- - --
Location
- - -- - -- - - -- - - - - - ----- - ------- --------
U.S.c. Citations
Total # of Counts -13- - - - - - - Dpetty OMisdemeanor [{]Felony
Title & Section Description of Offense Charged Count(s)
Set I 18:371.F CONSPIRACY TO DEFRAUD THE UNITED STATES I
Set 2 16:4 70.F ARCHAEOLOGICAL RESOURCE PROTECTION ACT 1,2,4,6,8,10,12
Set 4 - - - - -- -
Date: 12113/2016
ltl,~6)';; 1)1c:.,I"e.i
Defendant Information:
Juvenile: []Yes [i}No If yes, Matter to be sealed: []Yes DNo
Defendant Name JACKIE DALE ARNOLD
Alias Name _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____
Address Iuka, MS
DOB 1958 SS# xxx-xx-9017 Sex M Race W Nationality
-------- ---------
Represented by: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ __
Location Status:
Pretrial Release [{]v es ON 0 In Custody DYes [(]No
Federal State - - - Date of Arrest
-----------------
Location
-------------------------------
U.S.c. Citations
5 --------
Total # of Counts - Dpetty ON!isdemeanor [Z]Felony
Title & Section Description of Offense Charged Count(s)
Set 1 18:371.F CONSPIRACY TO DEFRAUD THE UNITED STATES 1
Set2 16:470.F ARCHAEOLOGICAL RESOURCE PROTECTION ACT 1,4,6
Set 4 - - - - - -
Location Status:
Pretrial Release [{]v es []No In Custody DYes [{)No
Federal State - - - Date of Arrest
-----------------
Location - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - -
U.S.c. Citations
Total # of Counts _9_ _ _ _ _ _ __ Dpetty []Misdemeanor [Z]Felony
Title & Section Description of Offense Charged Count(s)
Set \ 18:371.F CONSPIRACY TO DEFRAUD THE UNITED STATES 1
Set 4 - - - - - -
Location Status:
Pretrial Release [{]v es []No In Custody DYes [{]No
Federal State - - - Date of Arrest - - - - - - - - - - - - - - - - -
Location - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - -
V.S.c. Citations
Total # of Counts _5_ _ _ _ __ _ _ Dpetty []Misdemeanor [ZJFelony
Title & Section Description of Offense Charged Count(s)
Set 1 18:371.F CONSPIRACY TO DEFRAUD THE UNITED STATES 1
Set 4 _______
Date: 1211312016 Signature of AUSA -~-\-F~A. ~J'!.~L\. .- =-: : : :=" " "~-==-------
District Court Case Number:
Location Status:
Pretrial Release !ZJves []No In Custody DYes !ZJNo
Federal State - - - Date of Arrest
-----------------
Location ----------------------------------~-----
V.S.c. Citations
Total # of Counts _3___________ DPetty OMisdemeanor !ZJFelony
Title & Section Description of Offense Charged Count(s)
Set 1 18:371.F
CONSPIRACY TO DEFRAUD THE UNITED STATES 1
1,2
Set 2 16:470.F
ARCHAEOLOGICAL RESOURCE PROTECTION ACT
--------
1,3
Set 3 18: 1361.F
GOVERNMENT PROPERTY OR CONTRACTS (>$1000)
Set4
Date: 12/13/2016
District Court Case Number:
Signature of A USA - -~~
' ~W4~=---i'--
'- =- -==~~~-=-===
- -==----------
(To be entered by Clerk)
Case: 1:16-cr-00118-DMB-DAS Doc #: 1-7 Filed: 12/14/16 1 of 1 PageID #: 16
Location Status:
Pretrial Release [{]Yes []No In Custody DYes [{]No
Federal State - - - Date of Arrest
- - - - - - - - - - - - - -- - -
Location
-------------------------------
U.S.c. Citations
Total # of Counts _3_ _ _ _ _ _ __ Dpetty OMisdemeanor [{jFelony
Title & Section Description of Offense Charged Count(s)
Set 1 18:371.F CONSPIRACY TO DEFRAUD THE UNlTED STATES 1
Set 4
Alias Name
--------------------------------
Address Booneville, MS
DOB 1968 SS# xxx-xx-6808 Sex M Race W Nationality
- - -- ------- ---------
Represented by: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___
Location Status:
Pretrial Release [Z)v es []No In Custody DYes [(]No
Federal State - - - Date of Arrest
--------------------------
Location - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
U.S.c. Citations
Total # of Counts -5- - - - - - - - - - - Dpetty []Misdemeanor [Z]Felony
Title & Section Description of Offense Charged Count(s)
Set 1 18:371.F 1
CONSPIRACY TO DEFRAUD THE UNITED STATES
1,4,8
Set 2 16:470.F
ARCHAEOLOGICAL RESOURCE PROTECTION ACT
------
1,5,9
Set 3 18:1361.F
GOVERNMENT PROPERTY OR CONTRACTS (>$1000)
Set 4