Selected Prosecution Documents

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Here you can find selected documents related to the Jan. 6 criminal prosecutions. These documents are not meant to be exhaustive; rather, we highlight specific case filings that may be of interest to our readers. For a comprehensive overview of federal criminal cases and a repository of key documents from their dockets, see the Program on Extremism at George Washington University database here

Table of Contents: Selected Cases
Enrique Tarrio and Other Alleged Proud Boys, United States v. Ethan Nordean, 21-cr-175 (TJK), USDC, DDC
Josuha James, member of the Oath Keepers, U.S. v. Joshua James, 22-cr-15 (APM) (USDC, DDC)
Stewart Rhodes and Other Alleged Oath Keepers, U.S. v. Rhodes et al.
Daniel Rodriguez and Edward Badalian, U.S. v. Rodriguez, 21-cr-246
Jacob Chansley, the so-called “QAnon Shaman.” U.S. v. Chansley, 21-cr-3 (RCL) (D.D.C.)
Alleged Oath Keeper Co-Conspirators, U.S. v. Caldwell et al., 21-cr-28 (APM) (D.D.C.)
Jonathon Owen Shroyer, Infowars talk-show host, U.S. v. Shroyer, 21-cr-542 (TJK) (D.D.C.)
Alleged Proud Boys, U.S. v. Pezzola et al., 21-cr-52 (TJK) (D.D.C.)
Four Alleged Proud Boys Members, U.S. v. Nordean et al., No. 21-cr-175 (TJK) (D.D.C.)
Richard Barnett, photographed with his feet up on Nancy Pelosi's desk, U.S. v. Richard Barnett, 1:21-cr-38
Klete Derik Keller, Olympic gold-medalist swimmer, USA v. Klete Derik Keller, 1:21-cr-104
Edward Jacob Lang, USA v. Edward Jacob Lang, 1:21-cr-53

Enrique Tarrio and Other Alleged Proud Boys, United States v. Ethan Nordean, 21-cr-175 (TJK), USDC, DDC

  • Superseding Inditctment (June 6. 2022)
    • On June 6, a federal grand jury charged Proud Boys leader Enrique Tarrio and four other members of the far-right group with seditious conspiracy in connection with the Jan. 6 attack on the U.S. Capitol. The new superseding indictment charges Tarrio—along with existing co-defendants Dominic Pezzola, Ethan Nordean, Joseph Biggs and Zachary Rehl—with one count of seditious conspiracy and one count of conspiracy to prevent an officer from discharging any duties. 
  • Indictment of Enrique Tarrio
    • In a superseding indictment, Tarrio was added to an earlier conspiracy indictment of four other Proud Boys, or whom the original top defendant was Ethan Nordean. Tarrio is charged with conspiracy to corruptly obstruct an official proceeding, as well as aiding and abetting six other substantive felonies, including corruptly obstructing an official proceeding; assaulting law enforcement officers; impeding officers during a civil disorder; and destruction of government property. Tarrio was not present at the riot on Jan. 6, because he had been arrested in D.C. on Jan. 4 for an earlier offense and left the city, under court order to do so, on Jan. 5. He is nevertheless charged with these offenses for having allegedly helped plan them and because he was allegedly in electronic contact with his codefendants during the attack. An additional Proud Boy, Dominic Pezzola—who had previously been charged in a different Proud Boy conspiracy indictment—has now been moved to this indictment, as a sixth co-conspirator. Pezzola alone is charged with robbery of federal property for allegedly wresting a riot shield from a US Capitol Police officer. Pezzola allegedly used the shield to break out the first window pane on the Western Terrace, allowing the first rioters to jump into the building.

Joshua James, alleged member of the Oath Keepers, U.S. v. Joshua James, 22-cr-15 (APM) (USDC, DDC)

  • Joshua James's Signed Statement of Offense
    • In connection with his guilty plea to seditious conspiracy of March 2, Oath Keeper Joshua James signed this 15-page description of his activities before, during and after Jan. 6. The statement reports, for instance, that during the weeks leading up to Jan. 6, Oath Keeper leader Stewart Rhodes "instructed James and other coconspirators to be prepared, if called upon, to report to the White House grounds to secure the perimeter and use lethal force if necessary . . . against anyone who tried to remove President Trump from the White House, including the National Guard or other government actors who might be sent to remove President Trump as a result of the Presidential election." The statement also describes several weeks James spent in Texas with Rhodes after Jan. 6, during which he says he helped Rhodes buy additional firearms and plot additional violence.
  • Joshua James's Signed Plea Agreement
    • Oath Keeper Joshua James pleaded guilty, in a document filed March 2, 2022, to charges of seditious conspiracy and corruptly obstructing an official proceeding. He agreed to provide full cooperation and accepted a computation of a sentencing guidelines range calling for 87 to 108 months. He also signed the 15-page Statement of Offense posted separately.

Stewart Rhodes and Other Alleged Oath Keepers, U.S. v. Rhodes et al. 

  • Complaint
    • On Jan. 8, a grand jury indicted Stewart Rhodes, founder and leader of the far-right group Oath Keepers, in connection with the Jan. 6 attack on the U.S. Capitol. Charges against him and 10 other alleged Oath Keeper members include seditious conspiracy for organizing the plot to attack the Capitol. 
  • Stewart Rhodes Government Detention Memorandum

Daniel Rodriguez and Edward Badalian, U.S. v. Rodriguez, 21-cr-246

  • Superseding Indictment of Daniel Joseph Rodriguez
    • Rodriguez, 38, is accused of, among other things, twice using a small stun gun, or taser, to deliver electroshocks to the neck of Metropolitan Police Department officer Michael Fanone, who later lost consciousness and was admitted to the hospital. In this ten-count superseding indictment, he is charged with, inter alia, conspiracy; corruptly obstructing a Congressional proceeding; assaulting, impeding, and resisting a law enforcement officer with a deadly or dangerous weapon and inflicting bodily injury; obstructing law enforcement during a civil disorder; tampering with documents; theft of government property; and destruction of government property. The superseding indictment alleges that Rodriguez conspired with Edward Badalian, 26, as well as with a third individual whose name is redacted. The government alleges that the conspirators, in anticipation of attending the Jan. 6 Stop the Steal rally, collected weapons and tactical gear, including a taser, pepper spray, a baseball bat, gas masks, and walkie talkies. On Jan. 6, they allegedly stormed past barriers; participated in violent confrontations with police officers near the tunnel of the Capitol's Lower West Terrace; entered the Capitol; stole "emergency escape hoods" from the building; and later attempted to destroy incriminating photos and videos made by a co-conspirator. On January 5, Rodriguez allegedly posted to a Telegram chat group, "Let there be blood. Welcome to the revolution." Between 2:40pm and 3:38pm on Jan. 6, Rodriguez allegedly participated, with other rioters, in the "heave-ho" effort to break through police lines at the tunnel on the Capitol's Lower West Terrace; threw a flagpole at officers in the tunnel; and discharged a fire extinguisher at them. At about 3:18pm, he allegedly "twice applied the small black electroshock weapon to the back of Officer M.F.'s neck." Later, at about 4pm, he allegedly posted in his telegram chat group: "Omg I did so much shit m and got away to tell you later" and "Tazzzzed the fuck out of the blue[.]"
  • Transcript of Interrogation of Daniel Joseph Rodriguez of March 31, 2021
    • In this interrogation, defendant Rodriguez confesses to tasing Metropolitan Police Department officer Michael Fanone. (See, for instance, pages 44-45, 70-82, 102, 120, 121, 174. (Rodriguez's counsel has moved to suppress the confession alleging that it was obtained in violation of his rights under the Fifth Amendment and Miranda v. Arizona.)
  • Video of interrogation of Daniel Joseph Rodriguez (March 31, 2021)
    • These videos show Rodriguez's confession to tasing Metropolitan Police Department officer Michael Fanone. Rodriguez has moved to suppress his statements. (These prosecution exhibits, displayed by ProPublica, were released to the public by court order obtained by the Press Coalition, a consortium of 16 media outlets.)

Jacob Chansley, the so-called “QAnon Shaman.” U.S. v. Chansley, 21-cr-3 (RCL) (D.D.C.).

  • Indictment of Jacob Chansley

    • Jacob Chansley, also known as "Jacob Angeli" and more commonly known as the "QAnon Shaman," was indicted on six counts, including civil disorder, obstruction of an official proceeding, and several charges relating to his entry and conduct in the U.S. Capitol Building.  

  • Guilty Plea of Jacob Chansley and Statement of Offenses of Jacob Chansley

    • Jacob Chansley, the so-called QAnon Shaman, entered a guilty plea in September 2021. Chansley was among the first thirty rioters to enter the U.S. Capitol, wearing a viking hat, shirtless, covered in face paint and carrying a bullhorn and an American flag tied to a pole with a sharp object at the tip. Chansley admitted to the conduct set forth in a statement of the offense, including refusing to obey law enforcement officers' orders, using his bullhorn to "rile up the crowd and demand that lawmakers be brought out," scaling the Senate dais and writing a note stating "It's Only A Matter of Time. Justice Is Coming!" Chansley pleaded guilty to Obstruction of an Official Proceeding, 18 U.S.C. § 1512(c)(2). 

Alleged Oath Keeper Co-Conspirators, U.S. v. Caldwell et al., 21-cr-28 (APM) (D.D.C.)

  • Indictment of Alleged Oath Keepers Co-Conspirators

    • The Sixth Superseding Indictment charges 17 individuals in connection with the attack of January 6, 2021, including with conspiracy to interfere with the certification of the 2020 election. The indictment sets forth detailed allegations about the defendants' actions, which include coordinating with other members of the Oath Keepers and militia groups, bringing paramilitary gear and supplies such as firearms to Washington, D.C., and forcibly storming past Capitol Police and other law enforcement. 

  • Criminial Information in U.S. v. Wilson

    • The information charges alleged Oath Keeper co-conspirator William Todd Wilson with seditious conspiracy and obstruction of an official proceeding in connection with the larger seditious conspiracy case charged in U.S. v. Caldwell et al.

Jonathon Owen Shroyer, Infowars talk-show host, U.S. v. Shroyer, 21-cr-542 (TJK) (D.D.C.)

  • Criminal Complaint for Jonathon Owen Shroyer

    • Jonathon Shroyer is charged on three counts in connection with his alleged entry and conduct in restricted areas of the U.S. Capitol grounds, off-limits to the public, on Jan. 6. This criminal complaint attaches a detailed statement of facts, which includes allegations relating to Shroyer's comments in various Infowars promotional material calling for action to stop the certification of the Electoral College vote, as well as photos and descriptions of his conduct on Jan. 6. The statement of facts also references a deferred prosecution agreement into which Shroyer had entered in February 2020 as a result of his disorderly conduct and interruption of a House Judiciary Committee meeting in December 2019.  The deferred prosecution agreement was still active on Jan. 6.

Alleged Proud Boys Dominic Pezzola, William Pepe and Matthew Greene, U.S. v. Pezzola et al., 21-cr-52 (TJK) (D.D.C.)

  • First Superseding Indictment of Alleged Proud Boys Dominic Pezzola, William Pepe and Matthew Greene
    • The first superseding indictment lists ten counts. Seven counts are alleged against all three defendants, including conspiracy, obstruction of an official proceeding, multiple counts of obstructing law enforcement and disorderly conduct. Pezzola is charged with three additional counts, including assaulting an officer and robbery. The indictment alleges that Pezzola, Pepe and Greene coordinated with other members of the Proud Boys in advance of and during the events of Jan. 6, led a crowd to force their way through police lines, entered the Capitol after Pezzola used a riot shield he had stolen from a Capitol Police officer, engaged in violent acts against property and later celebrated their actions on social media.

Four Alleged Proud Boys Members, U.S. v. Nordean et al., (21-cr-175) (TJK) (D.D.C.)

  • First Superseding Indictment of Four Alleged Proud Boys leaders
    • The indictment charges four alleged leaders of different state chapters of the Proud Boys. It alleges that Nordean is president of his local chapter in Washington, Biggs an organizer from Florida, Rehl is president of his local chapter in Pennsylvania, and Donohoe is president of his local chapter in North Carolina. The defendants allegedly encouraged Proud Boys to come to Washington, D.C. on Jan. 6, instructed that members should avoid wearing attire identifying them as Proud Boys, obtained paramilitary gear, used equipment to coordinate and execute the the January 6 attack, forced their way past police lines, unlawfully entered the Capitol, destroyed government property, engaged in disorderly conduct, and celebrated their actions on social media.

Richard Barnett, photographed with his feet up on Nancy Pelosi's desk, U.S. v. Richard Barnett, 1:21-cr-38

  • Indictment of Richard Barnett, who was famously photographed with his feet up on Nancy Pelosi's desk
    • The seven-count indictment charges Barnett, an Arkansas man, with three felonies, including corruptly obstructing a congressional proceeding and entering and remaining in a restricted building with a deadly or dangerous weapon. The alleged weapon was a ZAP Hike N Strike Stun Gun Walking Stick.
  • Government's Opposition to Defendant's Motion for Modification of Bail
    • On April 12, 2021, the government opposed Barnett's motion for conditional pretrial release. Recapping and supplementing the charges of the criminal complaint and indictment, it alleges that Barnett entered the Capitol with a stun gun; posed for photos in Speaker Nancy Pelosi's office with his feet up on her desk; left her a note saying "Nancy, Bigo was here, you bitch"; confronted police officers; used a bullhorn to rile up the crowd; and remarked that there is an ongoing "civil war." The government also alleged that Barnett had a prior history of threatening conduct with firearms. On April 28, 2021, Judge Christopher Cooper ordered Barnett released with conditions. 

Klete Derik Keller, Olympic gold-medalist swimmer, USA v. Klete Derik Keller, 1:21-cr-104

  • Statement of Offense (accompanying guilty plea) of Klete Derik Keller, Olympic gold-medalist swimmer
    • In late September 2021, Keller, a 6'6" Olympic gold-medalist swimmer, pleaded guilty to the felony of corruptly obstructing a congressional proceeding. He admitted entering the Capitol to stop or delay the Electoral College vote count, repeatedly refusing police orders to leave the Rotunda, "shaking law enforcement officers off" him by jerking his elbow when they attempted to remove him, and later destroying his phone, memory card, and the USA jacket he'd worn during the riot. Later in January, he turned himself in. His guilty plea includes a cooperation agreement. His sentencing guidelines call for a 21-27 month sentence.

Edward Jacob Lang, USA v. Edward Jacob Lang, 1:21-cr-53

  • Government Opposition to Defendant's Motion for Release
    • Edward Jacob Lang was arrested on Jan. 16, 2021 and indicted on Jan. 29, 2021. His 11-count indictment includes three felony counts of assaulting, resisting, and impeding certain law enforcement officers (including two counts involving use of a deadly or dangerous weapon); three felony counts of civil disorder; and one felony count of corruptly impeding a congressional proceeding. According to the government, Lang was involved in fights with the police around the Capitol's Lower West Terrace tunnel for almost two-and-a-half hours, from 2:40 p.m. to nearly 5 p.m.. Incriminating stills and video of him were allegedly captured from Capitol surveillance cameras, police body-worn cameras, and on videos recovered from Lang's own phone or his Instagram or Facebook accounts. He was allegedly among the first rioters to enter the tunnel at 2:41 p.m.; was with them when they broke windows and yelled that police officers were "enemies of the state." He and another rioter allegedly "violently pushed a door against an officer's head" while Lang "kicked at that officer." He then briefly left the archway, filmed a selfie video saying "we are the real men." He later posted a still from that video on Facebook saying, "Arrest me. You are on the wrong side of history." At 3:08 p.m. he allegedly reentered the tunnel and pushed in unison with other rioters, chanting "Heave-ho," trying to break through a line of officers. During this operation another police officer was being "violently crushed against the first set of doors." Lang was pushed out of the tunnel but allegedly reentered at 3:15 p.m.. He was pushed out again. He then allegedly took more selfies—later posted to Instagram--in which he bragged of having taken "a little pepper spray in the morning." At about 3:50 p.m. the violence resumed, with Lang allegedly "one of the leaders." The government alleges that he grabbed and hit an officer repeatedly. He "crowd-surfed to commit violence," the government alleges. He "repeatedly kicked" a detective who had fallen, according to this filing. He then took another break to film another video which he later posted to Instagram, the Government claims. Later, at about 4:43 p.m. he allegedly struck another officer with a stolen riot shield multiple times. Then he allegedly slammed the riot shield on the ground several times to "rile" the crowd, while other rioters threw "poles, plastic cones, desk drawers, and sticks" and the officers. Lang then, between 4:55-5 p.m., allegedly attacked officers with a bat another rioter had handed him. He "varied between low swings, overhead swings, and thrusts," according to the government. One officer struck "had trouble standing" that night, "limped for days," and "the swelling took a month to subside," according to the filing. The next day, Lang participated in a nearly 45-minute interview on Instagram in which he said, 'This was no mob ... This was an organized unit of patriots trying to take on tyrants. ... This was patriots ... on a mission to have the Capitol building. To stop the election from being stolen so that we at least have one presidential veto left from all of these bullshit laws and restrictions." U.S. District Judge Carl Nichols denied Lang's motion for release and, in early October, Lang appealed.