Runnels Indictment
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Transcript of Runnels Indictment
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7/26/2019 Runnels Indictment
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IN THE UNITED STATES DISTRICT COURT FOR THEWESTERN DISTRICT OF MISSOURI
WESTERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
TIMOTHY RUNNELS,[DOB: 07/26/1983]
Defendant.
Case No. ___________________________
COUNTS ONE AND TWO18 U.S.C. 242 (Deprivation of Rights)NMT: 10 YearsNMT: 3 years Supervised ReleaseNMT: $100,000 FineClass C Felony
COUNT THREE18 U.S.C. 1519 (Obstruction of Justice)NMT: 20 Years
NMT: 3 Years Supervised ReleaseNMT: $100,000 FineClass C Felony
COUNT FOUR18 U.S.C. 1512(b)(3) (Obstruction of Justice)NMT: 20 YearsNMT: 3 Years Supervised ReleaseNMT: $100,000 FineClass C Felony
$100 Mandatory Special Assessment for EachCount
INDICTMENT
The Grand Jury charges that:GENERAL ALLEGATIONS
1. At all times relevant to this Indictment, the Independence Police Department was a
law enforcement agency in the Western District of Missouri. Among other functions, the
Independence Police Department investigated crimes committed in Independence, Missouri.
2. At all times relevant to this Indictment, employees of the Independence Police
Department were responsible for conducting themselves in compliance with federal, state, and
local laws, including the United States Constitution.
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3. At all times relevant to this Indictment, defendant TIMOTHY RUNNELS was
employed as a police officer at the Independence Police Department.
COUNT ONE
The Grand Jury further charges that:
1. Paragraphs one through three of the General Allegations are incorporated by
reference in this count.
2. On or about September 14, 2014, in the Western District of Missouri, TIMOTHY
RUNNELS, the defendant herein, while acting under color of the laws of the State of Missouri,
willfully deprived B.M. of the right secured and protected by the Constitution and laws of the
United States to be free from unreasonable seizure by one acting under color of law. Specifically,
the defendant continuously deployed a Taser against B.M. while B.M. was on the ground and not
posing a threat to the defendant or others. The offense involved the use of a dangerous weapon
and resulted in bodily injury to B.M.
All in violation of Title 18, United States Code, Sections 242.
COUNT TWO
The Grand Jury further charges that:
1. Paragraphs one through three of the General Allegations are incorporated by
reference in this count.
2. On or about September 14, 2014, in the Western District of Missouri, TIMOTHY
RUNNELS, the defendant herein, while acting under color of the laws of the State of Missouri,
willfully deprived B.M. of the right secured and protected by the Constitution and laws of the
United States to be free from unreasonable seizure by one acting under color of law. Specifically,
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the defendant deliberately dropped B.M. face first onto the ground while B.M. was restrained and
not posing a threat to the defendant or others. The offense resulted in bodily injury to B.M.
All in violation of Title 18, United States Code, Sections 242.
COUNT THREE
The Grand Jury further charges that:
1. Paragraphs one through three of the General Allegations are incorporated by
reference in this count.
2. On or about September 14, 2014, in the Western District of Missouri, TIMOTHY
RUNNELS, the defendant herein, in relation to and in contemplation of a matter within the
jurisdiction of the Federal Bureau of Investigation, an agency of the United States, knowingly
altered, concealed, covered up, falsified and made false entries in a document with the intent to
impede, obstruct, and influence the investigation and proper administration of the matter within
federal jurisdiction. Specifically, the defendant authored and submitted a false and misleading
official police report, which falsely described and omitted details concerning the force that he used
against B.M. on September 14, 2014, and the circumstances that led to B.M.s bodily injuries on
that day, with the intent to obstruct any investigation into the deprivations of constitutional rights
described in Counts One and Two of this Indictment.
All in violation of Title 18, United States Code, Section 1519.
COUNT FOUR
The Grand Jury further charges that:
1. Paragraphs one through three of the General Allegations are incorporated by
reference in this count.
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2. On or about September 16, 2014, in the Western District of Missouri, TIMOTHY
RUNNELS, the defendant herein, did knowingly attempt to corruptly persuade and engage in
misleading conduct toward investigators from the Independence Police Department, with the
intent to hinder, delay, and prevent communication to a law enforcement officer of the United
States of information relating to the commission or possible commission of a federal offense,
namely, the deprivations of constitutional rights described in Counts One and Two of this
Indictment. Specifically, the defendant knowingly made a false statement and intentionally
omitted information from a statement, thereby causing a portion of the statement to be misleading,
concerning the force that he used against B.M. on September 14, 2014, and the circumstances that
led to B.M.s bodily injuries on that day.
All in violation of Title 18, United States Code, Section 1512(b)(3).
A TRUE BILL.
____3/26/15___________________ ____/s/ Helen A. Chaffin_____________DATE FOREPERSON OF THE GRAND JURY
___/s/ David Ketchmark___________David KetchmarkFirst Assistant United States Attorney
___/s/ Shan Patel_________________Shan PatelTrial AttorneyCivil Rights Division
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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MISSOURI
CRIMINAL CASE COVER SHEET
Division of Filing
Western Central Southwestern
St. Jose ph Southern
Place of Offense
Jackson
County and
elsewhere
Matter to be Sealed
Secret Indictment Juvenile
Defendant Information
Defendant Name Timothy Runnels
Alias NameBirthdate 07/26/1983
Related Case Information
Superseding Indictment/Information Yes No if yes, original case number
New Defendant Yes No Prior Complaint Case Number, if any
Prior Target Letter Case Number, if any
U.S. Attorney InformationAUSA David Ketchmark
Interpreter Needed
Yes Language and/or dialect
No
Location StatusArrest Date
Currentl in Federal Custod
Currently in State Custody Writ Required Yes No
Currently on Bond Warrant Required Yes No
U.S.C. CitationsTotal # of Counts 4
SetIndex Key/Code/Offense
LevelDescription of Offense Charged Count(s)
1 18.242.F/9901/4 Deprivation of Rights 1-2
2 18.1519.F/9992/4 Obstruction of Justice 3
3 18.1512B.F/9992/4 Obstruction of Justice 4
4
5
Date 3/26/15 Signature of AUSA /s/ David Ketchmark
Case 4:15-cr-00106-DW Document 1-1 Filed 03/26/15 Page 1 of 1