Fowler complaint

Joel Daniel Fowler Co. Atty. Complaint No.: 2130458-1 Court File No.:

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STATE OF MINNESOTA

COUNTY OF RAMSEY

DISTRICT COURT

SECOND JUDICIAL DISTRICT

COURT FILE NO.: _____________

PROSECUTOR FILE NO.: 2130458

State of Minnesota,

Plaintiff,

v.

Joel Daniel Fowler

(DOB: 04/12/1991)

3755 Quebec Ave. South St. Louis Park, MN 55426,

FELONY

CRIMINAL COMPLAINT

Summons Warrant

Order of Detention

Amended

Certified Juvenile

EJJ

Defendant.

The Complainant, being duly sworn, makes complaint to the above-named Court and states that there is

probable cause to believe that the Defendant committed the following offense(s):

COUNT 1 On or about the 27th day of May, 2014, in Ramsey County, Minnesota, the defendant, JOEL DANIEL

FOWLER, being 18 years of age or older, by means of the Internet or a computer, computer program,

computer network, electronic communications system, or telecommunications, wire, or radio communication

system, with intent to arouse the sexual desire of any person, did wrongfully and unlawfully engage in

communications relating to or describing sexual conduct with a child or someone the person reasonably

believes is a child, 15 years or age or younger.

Said acts constituting the offense of Electronic Solicitation of a Child in violation of MN Statute:

§609.352.2a(2); 609.352.4

Maximum Sentence: 3 years or $5,000 fine or both.

COUNT 2 On or about the 27th day of May, 2014, in Ramsey County, Minnesota, the defendant, JOEL DANIEL

FOWLER, being 18 years of age or older, by means of the Internet or a computer, computer program,

computer network, electronic communications system, or telecommunications, wire, or radio communication

system, with intent to arouse the sexual desire of any person, did wrongfully and unlawfully solicit a child or

someone the person reasonably believes is a child, 15 year of age or younger, to engage in sexual conduct.


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Said acts constituting the offense of Electronic Solicitation of a Child in violation of MN Statute:

§609.352.2a(1); 609.352.4

Maximum Sentence: 3 years or $5,000 fine, or both.


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STATEMENT OF PROBABLE CAUSE

The Complainant states that the following facts establish probable cause:

On May 27, 2014, Saint Paul Police Sergeant Keller was conducting an undercover investigation and reviewing

Craigslist ads for people who may be interested in having sexual contact with a minor. Sergeant Keller entered

the search term “high school” in the casual encounters section and located an ad entitled “High School – m4w –

23.” A photo of four young women in graduation caps accompanied the ad which read:

It’s graduation season. I’m looking for a soon-to-be or recent high school graduate who

wants to play with a just out of college guy. I was just at a HS graduation and watching

the girls really made me miss high school and the fun those girls are! I live in the West

Metro. 23 years old. 190lbs. 6’1”. I’m DDF and ready to get to know someone younger

than me.

Sergeant Keller responded to the ad posing as a 14-year-old girl who was with her friends. He asked the poster,

“how yung is too yung 4 u?” The poster replied, “How old are you guys? Do you drive?” Sergeant Keller

responded, “gonna be 15 in July. don’t drive but will leav school and meet u. ur ad said u want to play…..wat

do u want 2 do” The poster responded, “Send me a pic. i want to fuck.”

Sergeant Keller sent the poster an age regressed photo of a female law enforcement officer’s face. The poster

responded with a photo of a male naked from the waist up. The poster and Sergeant Keller continued to

communicate back and forth and discussed the location of Cherokee Park in Saint Paul as a meeting location.

Sergeant Keller provided the poster with a telephone number and began receiving text messages. The poster

identified himself as “Blake” but a law enforcement database showed that the phone number generating the

texts was associated with JOEL DANIEL FOWLER (DOB: 4-12-1991).

The poster requested another picture and Sergeant Keller sent him another photo of an employee assigned to the

Minnesota Bureau of Criminal Apprehension. The poster agreed to meet at 1:30 pm in Cherokee Park. The

poster then texted, “You said your friends think I’m cute” Sergeant Keller replied, “yess” The poster asked,

“Will i fuck all of you or just you” Sergeant Keller responded, “can u bring protection?” The poster responded,

“Yes” and “Where are we fu c king” Sergeant Keller replied, “we could do it in ur car.” The poster indicated

he would arrive in a silver Honda Accord.

Law enforcement officers set up surveillance in the Cherokee Park area. Officers saw a silver Honda Accord

arrive being driven by Fowler. Officers arrested Fowler and found two condoms in his front left pocket and two

condoms in his back left pocket.

Fowler was advised of his constitutional rights and agreed to speak to police. Fowler said he is a middle school

teacher and has a master’s degree in education. Fowler called in sick the day he was arrested. Fowler was told

he was in jail for solicitation of a minor. When asked if he did that, Fowler replied, “Not intentionally.” He

explained that he met someone online and was going to meet them when he was stopped by the police. Fowler

denied knowing the age of the person he was going to meet and denied she had told him her age. They were

going to meet at 1:30 pm and see what happened. When asked if that meant he was going to have sex with her,

Fowler admitted, “Eventually.” He claimed he had never seen the girl and he denied she sent him a picture of

her face.


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Sergeant Keller told Fowler that he knew Fowler was not being truthful. Fowler admitted the person he was

communicating with told him she was going to turn 15, but he wanted to see her. He didn’t know if she was

lying about her age and said that if he saw her he could back out of it. When asked how he planned on

verifying the girl’s age, Fowler indicated he planned on asking her.

Fowler said he had posted five different ads on Craigslist and reposted them several times since 2012 because

he was bored. Fowler said this was the first posting where he specifically indicated he was looking for someone

younger than him. He denied ever meeting anyone from an ad he posted. Fowler denied having complaints

against him at the school where he taught or any inappropriate contact with children.


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Complainant requests that Defendant, subject to bail or conditions of release, be:

(1) arrested or that other lawful steps be taken to obtain Defendant’s appearance in court; or

(2) detained, if already in custody, pending further proceedings; and that said Defendant otherwise be dealt

with according to law.

COMPLAINANT’S NAME:

Jeffrey Keller

COMPLAINANT’S SIGNATURE:

____________________________________

Subscribed and sworn to before the undersigned this ______ day of _________, 20_____.

NAME/TITLE:

____________________________________

SIGNATURE:

____________________________________

Being authorized to prosecute the offenses charged, I approve this complaint.

Date: 05/29/2014

PROSECUTING ATTORNEY’S SIGNATURE:

____________________________________

Name: Derek Fitch

Assistant Ramsey County Attorney

345 Wabasha Street North, Suite 120

St. Paul, MN 55102

651-266-3222/mc

Attorney Registration #328339


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FINDING OF PROBABLE CAUSE From the above sworn facts, and any supporting affidavits or supplemental sworn testimony, I, the Issuing Officer, have determined

that probable cause exists to support, subject to bail or conditions of release where applicable, Defendant’s arrest or other lawful steps

be taken to obtain Defendant’s appearance in court, or Defendant’s detention, if already in custody, pending further proceedings.

Defendant is therefore charged with the above-stated offense.

SUMMONS THEREFORE YOU, THE ABOVE-NAMED DEFENDANT, ARE HEREBY SUMMONED to appear on the ____ day of

____________, 20___ at _______ before the above-named court at _______________________________________________ to

answer this complaint. IF YOU FAIL TO APPEAR in response to this SUMMONS, a WARRANT FOR YOUR ARREST shall be issued.

WARRANT

Execute in MN Only Execute Nationwide Execute in Border States To the Sheriff of the above-named county; or other person authorized to execute this warrant: I hereby order, in the name of the State

of Minnesota, that the above-named Defendant be apprehended and arrested without delay and brought promptly before the above-

named court (if in session), and if not, before a Judge or Judicial Officer of such court without unnecessary delay, and in any event not

later than 36 hours after the arrest or as soon as such Judge or Judicial Officer is available to be dealt with according to law.

ORDER OF DETENTION Since the above-named Defendant is already in custody, I hereby order, subject to bail or conditions of release, that the above-named

Defendant continue to be detained pending further proceedings.

Bail: $10,000.00

Conditions of Release: No unsupervised contact with females under the age of 16. This complaint, duly subscribed and sworn to, is issued by the undersigned Judicial Officer this ______ day of _____________,

20_____. JUDICIAL OFFICER: NAME: TITLE:

SIGNATURE: ___________________________________

Sworn testimony has been given before the Judicial Officer by the following witnesses:

COUNTY OF RAMSEY

STATE OF MINNESOTA

Clerk’s Signature or File Stamp:

STATE OF MINNESOTA

Plaintiff, RETURN OF SERVICE I hereby Certify and Return that I have served a copy of this COMPLAINT upon the Defendant herein named. Signature of Authorized Service Agent: _________________________________

vs.

JOEL DANIEL FOWLER Defendant.


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FINDINGS OF FACT

Probable cause found that defendant committed the offenses charged.

Ordered defendant's motion to dismiss denied.

Plea of not guilty to all counts entered.

Trial and hearing on all issues set.

Dated: ________________________

_______________________________________

JUDGE OF DISTRICT COURT


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DEFENDANT DATA / CHARGE SHEET – ATTACHMENT A

DEFENDANT NAME:

JOEL DANIEL FOWLER

DOB: 04/12/1991

Defendant alias name(s):

Alias DOB(s):

Defendant last known

address:

3755 Quebec Ave. South

St. Louis Park, MN 55426

State ID:

MN14H44308

Fingerprint ID: 303535 FBI ID: 580410AE7 St. Paul PD ID: Offender ID:

OTHER DEFENDANT / CASE IDENTIFIERS:

Fingerprinted? No Yes

Handgun permit? No Yes (Issuing Agency: )

Location of violation:

IF DRIVING OFFENSE:

Driver's License Number: Issuing State:

License Plate Number: Issuing State:

Accident Type: check all that apply

No injury/no damage Property Damage

Personal Injury Fatality

Blood Alcohol Concentration (BAC):


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FELONY WARRANT AND ORDER OF DETENTION COMPLAINT

CT

NO OFFENSE

DATE STATUTE

TYPE STATUTE

NBR STATUTE

DESCRIPTION OFFENSE

LEVEL MOC G

O

C

AGENCY

ORI

CN NBR

FUNCTION

1 05/27/2014 Charge 609.352.2a(2) Engage in Electronic

Communication Relating

or Describing Sexual

Conduct with Child.

Penalty 609.352.4 Solicitation - Solicit Child

in Person or via Computer

or Internet - Sexual

Conduct - Felony Penalty

F Z1106 N St. Paul Police Dept.

ORI - MN0620900

CN - 14103582

Charging

2 05/27/2014 Charge 609.352.2a(1) Solicit Child or Believe to

be a Child Through

Electronic Communication

to Engage in Sexual

Conduct

Penalty 609.352.4 Solicitation - Solicit Child

in Person or via Computer

or Internet - Sexual

Conduct - Felony Penalty

F Z1106 N St. Paul Police Dept.

ORI - MN0620900

CN - 14103582

Charging

Fowler complaint

Documents

Transcript of Fowler complaint