Runnels Indictment

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.

Case 4:15-cr-00106-DW Document 1 Filed 03/26/15 Page 1 of 4


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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





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





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






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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

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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

Runnels Indictment

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