Brian Campbell court

Brian Campbell, left, appears for a court hearing in March.

Brian Campbell, whose Far West Side apartment was found a year ago to contain a vast array of chemicals and materials used for making pipe bombs, appeared to be contemplating an attack on the UW-Madison campus, a prosecutor alleged in a sentencing memorandum filed Tuesday.

But Campbell’s lawyers accused Assistant District Attorney John Rice, who drew comparisons between Campbell and infamous domestic terrorists like Timothy McVeigh, of making assertions that go far beyond what Campbell last month admitted he did as part of a plea agreement.

In a 39-page memorandum filed ahead of a sentencing hearing for Campbell on Friday, Rice wrote that in addition to the dangerous chemicals and materials for making explosives that investigators found in Campbell’s apartment, Campbell had also searched the internet for instructions on making explosives and downloaded videos on the process, and had drawn maps that represented the tunnels between buildings on the UW-Madison campus.

The maps had lines drawn in blue, green and red ink, with specific locations circled, Rice wrote, and indicated Campbell “had mapped out enough of the underground tunnel system such that he could have easily planted an explosive device within.”

“These items viewed together suggest that the defendant was planning something very destructive,” Rice wrote. He added that “it seems impossible to ignore the fact that the defendant’s conduct strongly resembled the precursors and/or preparations needed to complete an act of domestic terrorism.”

Campbell’s attorney, Tracey Wood, said she and co-counsel Sarah Schmeiser are investigating whether Rice’s memorandum constitutes a breach of the plea agreement reached between prosecutors and Campbell. He pleaded no contest in January to second-degree reckless endangerment and possession of improvised explosives.

Under the agreement, prosecutors can seek no more than three years in prison for Campbell. That’s what Rice indicated in the memorandum that he would seek Friday from Circuit Judge Susan Crawford, who is free to sentence Campbell up to the maximum allowed for the two convictions.

But Wood said that Rice, with his memorandum, may be attempting an end-run around the plea agreement, arguing by implication that the sentence should be even longer than the one he’s recommending.

“We believe Judge Crawford will sentence based upon those facts to which Brian admitted and for which he accepts full responsibility and not upon mere speculation,” Wood said.

Chip on his shoulder

Rice’s memorandum paints Campbell as intelligent, arrogant and anti-social, and as someone with a chip on his shoulder. In Campbell’s case, he wrote, it was over a 2016 incident for which Campbell was charged with battery for choking a colleague at Hoofers, the Wisconsin Union sailing club.

Campbell also verbally sparred with the managers of his apartment building on Timber Lake Trail, Rice wrote. The Feb. 20, 2018, discovery of the chemicals, detected when residents reported a strong smell in the building, forced the weeklong evacuation of the building.

Rice wrote that a chemical found in Campbell’s apartment was the same kind that caused an explosion that killed another would-be bomb maker in Beaver Dam less than two weeks after Campbell’s arrest.

But the “most obvious comparison,” Rice wrote, is to Timothy McVeigh, who bombed the Murrah Federal Building in Oklahoma City in 1995. He notes that Campbell “had all of the necessary ingredients” in his apartment to build the same type of bomb as the one McVeigh used.

Password: ‘McVeigh’

Rice also twice noted that one of Campbell’s computer passwords was “McVeigh,” which Campbell initially claimed to police is his mother’s maiden name. It isn’t.

“The reason these cases are important to provide context,” Rice wrote, “is because given some of the similarities, this case begs the question, ‘Why would Brian Campbell do what he did?’”

McVeigh and other domestic terrorists, such as Ted Kaczynski, Rice argued, felt aggrieved. Campbell, he wrote, was aggrieved by a ban from the UW-Madison campus after the Hoofers incident.

“When someone has been aggrieved and when they have both isolated themselves and taken meaningful steps towards creating something destructive,” Rice wrote, “there is legitimate reason to fear that person doing something lethal in the future. The defendant’s conduct resembles someone who was working towards becoming a homegrown domestic terrorist right here in Madison.”

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