Jcronimo Y{)))<;Z Piigc: I of 10 Co, Atiy Compininf No: 0620373879 STATE OF MINNUSOTA COUNTY OP KAMSBY w OISTRJCT COURT RAMSEY DISTRICT COURT SKCOND JUDICIAL DISTRICT COURT FILE NO.: PROSECUTOR FILK N0.:0620373879 State ofMinncsofa, Pining FELONY CUJMJNAL COMPLAINT Jeronimo Yanex Summons D Wnrrani D Order of Detention a Amended a CcrHf'icd Juvenile a EJJ Dcfeiuhmt. The Complainant, being duly sworn, makes complaint to the abovc-named Court and states that there is probable cause to believe fhdi the Defendant committed the foliowlng o(TenKe(s): COUNT 1 On or about Juiy 6, 2016^ in Runivsey Coun(,y> Miiiticsota, Jeronmio Yanez caused the death ofPhihndo Castile by cuipable ncgtlgence whereby Jeronimo Yancz created an unreasonable risk, and consciously took the chance ofcausing death or grciil bodily liarm to another. Said acts constituting the offence o['IVtans!aughter - 2nd Degree" Culpitble Negligence Creating Unrcasoniibic Risk in viotation of: §609.205.(1). Mtiximum Senfcncc: 10 years or $20,000 or both COUNT 2 On or about July 6, 2016, in Ram.scy County, Minnesota, Jeronimo Yancx intentionally discharged a fn'CtU'm under circumstances thai endangcrccl the safety of another Diamond Reynolds, Said acts constitLiting the offcnse ofDsingcrous Wcapons-Intetitionnl Dtsdinrge of Firenrm Th;if Endangers Safety in violation of: §609.66.la(a)(2). Maximum Sentence; 5 ycm's or $10,000 or both. .fcronjino Ynncy. Page; 2 oflO Co. AltyCompiaini No: 0620373879 COUNT 3 On or t\bo\}{ July 6, 2016, in Ramscy County, Minnesota, Jcronimo Yancx intentionally discharged a firearm under circum stances that endangered the safety of another D.1?.R. Said ads constituting (he ofTensc of Dangerous Wciipon.s-Intcntionnl Discliin'ge of Fircttrni Thnl Kndnngcrs SiiJEcty in violation of; §609.66, la(a)(2). Maximum SciUcncc; 5 years or $10,000 or both, Jcronltno Co, Ally Compl;un( No; 0620373879 Ynncx Pitgc; 3 of 10 .STATEMENT OF PROBAHLE CAUSIS The Complainanl states ihat the Jbtlowing facts establish pi'obrtbk caiLSc: Your complainant is Ooug Hcnnlng, Special Agent, Min-nesola Bvn-cau ofCrttnin£)l Apjirdiciision. He stales that the following is true, correct, iinci eslabIJshes probable awsc: On July /2, 2016, a Super USA convenience slorc .in Lauclci'dale, Minnesola, way robbed by two black maies. Video surveillance oftbiil robbery showed two black maEc yui>pcct$, bolh with dreacltocl Yancz inferruptcd and caJmly replied "Okay" and placed his nghi hand on ihc hoJsicrofhLs own Jiolstercd gun. Jcrotiinio ynncx Pagy: 4 of }Q Co. Atty ComphHiU No; 0620373K79 9:05:55 PM-9:06:02 PM - Yaiiey, said "Okay, don't rcadi for it, then,"' Castile responded: I m...I in,..[imiudiblc] rcdchin^.../* before being again interrupted by Yane/., whoyaid "Don't pull it out." Cusliie responded 'Tm nol pulling it out", and Rcynokly iilso sFiid "He's not pulling it out," Yanez screamed "Don't pull il out" and quickly pulled h\s own gun v/Uh liis right hand while lie reached inside the driver's side window with his icJl hand. Yancz removed his left arm from the car, fhcn fired seven shots in [he dircclion oI'CEistile in rapid succession. The sevenlli shot was fired at 9:06:02 P.M. During the incident, Kauscr did nol touch or remove his gun. 9:06:03 PM-9:06:04 P.M." Reynolds yelled "You just kilicd my boyfriend!" 9:06:04 IJ.M,-9;06:05P.M. - Castile moaned 'l pull it out!" Reynolds responded "He wasn t. Vanex yelled "Don't move! Fuck!" Audio and video wafi also livesfrenmcd by Reynolds on Facebook imn-iediatcly after the sliooting and while Yanez had h\s gun drawn and pointed toward the mortally womided Castilc. In the audio recorded by this Hvcstream starting at 9:06:42 P.M,, Reynolds staled that Castilc "... was trying to get out his ID in his wallet out his um pocket and he let the officer know that h& was, reach he iuid a firearm and he was rcuohing for his wallet and the oFFicerjust shot him in his arm.1' The fbllowing inlerchange between Yafie7. and Reynolds was also recorded; Reynolds: "Stay with inc. We got pulled over For a busted tail light in the back. And the poJicejust he\s, hc'K, he's covered. Ho, they just killed my boyfriend, Yancx: "Fuck" Reynolds: "He's licensed. He's earned, he is lic&nKed to carry." Yancz: "M«1amjust keep youi* handy whyre Ihcy are. Reynolds; "I wili sir. No wome.s, I wiil." Yanez: "Fuck!" Reynolds; "Hejusf shot his arm off. We got pulled over..." Yancz; "fuck" Reynolds: "...on Larpcnt&ur." Yancz; "I told him not to reaoh for it. I told him (o get his hand off of it." Reynolds: "He hud» you told him to get his ID sir and ins driver^ license. Oh my God please don't tell me lie's dead," Assisting officers arrived, unbucklecl Caslile's scatbeli, and removed Castile irom tlic vehicle. They performed CPR on Casttie until paratnedics arrived ajid took over. When officers and paramedics rollect CaslUc; to his right side so thai a backboard could he put under him, tlicy saw and removed a .40 caiiber semiautomatic handgun from inside (he large right front pocket of Castile's shorts (measuring approximaldy 12" deep x 6" wide). The gun contained a loaded maga^ne but did not lmv& a round in (lie chamber. CasfU^ was transported to Hcnncpin County Medical Center (HCMC). In the I ICMC omergeucy department medical personnel recovered a hoister and wallet from one ofCasUie'.s pockets, aithough it was unclear which pocket these items were in at the time ofthc shootmg. In Castilc's wallet w^s liis Minnesom Driver's License and his Permit to Carry a Pistol. Within minutes after the .shooting^ Yanyx .spoke with ^aint Anthony Police Officer Tressa Sunde at the scene of the shooting. During that conversation, which was captured on Yancz's squad microphone and recorded at 9:13:00 I\M., Yanw, said; "He [Castllc] WEIS sitting EJI the car, seat belted. I told ltim» can J see yovr license. And then, he told me he Eiad a Hrearm. I told liim not to reach for it and (sigh) when he went down to grab, I told him not to reach for it (clears throat) and then lie kept it right there, finct I iold hhn to take his hands offofit, and Ihcn he (sigh) he had his, his grip a tot wider than a wallet," Juronjnio Crt. Ally Comphtint No; 0620373879 Yiincx p^ge: 5 of 10 Yanez wenl on to say: "And I don 1 know where Ihc gun was, he didn't lell me where the fucking gun was and then it way just getting hiriky, \w gave, he was just staring straight ahead^ aiul the I was getting fucking nervous, and then 1 told fiinit I know I fucking lold him to get bin fucking hand off bis gun." Yanez was interviewed by BCA mvesligafors the following day on July 7 al \'A1 P.M, During Ihat mfcrvicw Yanc'/ said liiat wlicn lie first ti])proacl-ied Castilc's driver's side window lie sinelled burnt n-iut'ijuana comuig from inskic the vehicle. Yimiez said iiu also noticed a female child in the back seat and an uclult female in the front pysyengcr seal. Yancz described Castilc as inilially having "hili icR ann over (lie Hlcerhig wheel" will) "both hands in view/' Yunox siiki he did not mention anylhing about the marijuami smell to Caslilc yu ^ not (o scare [Castile] or have him react in a defcnyivc manner." Ynnez yaid that Ca.stiic "kept 1us» hands in view" up until the point, at which lie asked for Castilc\s license and insurance. A.ftcr receipl of his proof of insurance, Yane/c said Castilc toid him that lie had a firearm at the same time that "he rencinxr down between hly riglU leg, ills right thigh arcfi and the center console.*1 Ynncz said that, ay Castile was reacliing down to his right, "lie lurncd his shoulder, kept his left hand on the steering wheel ?md then cantcct Ins upper body and blocked my view of his right hand." Yanezsakt: "And, at thai point I, was sctircd and 1 was, in fear for my life and my partn&r's lile. And for the little girl in the back and the front seat passenger and he dropped his hand down and, can't reinember what I was telling him but I was telling something as his hand went down I think. And, he put his hand around something. And his hand made like a C shape type urn type shape and it appeared to nic iha( he was wrapping somclhmg around his fingcry and almost like ifl were to put my uh hand around my gun like putting my hand up to the butt ofthc &un/ ... And then I loyt view of il, Cu/. he kept cai-ithig bis yliouldcf and then I believe I told him again 1 can't remember don't do it. And then he stilt kcpi moving hi>s hand and at this point I looked and saw soinetiiing in hLs hand. It was dark inside the vehicle. I was trying to fumble my w^y through under stress to look and see what it was to make sm'c uh what I was seeing. But I was nt given enough time and like I said ho had no regard for what I was saying, Didn'l follow my dircclion. And, uh he started t'cEiching out and then pulling uh awa-y tiom his uh his right thigh. I don*t know if it was in his pocket or in between the seats oi* Ihe center console. But I, I know lie had an object and it was dark. And lie was pulling it out with Ills right hand. And as he was pulling it out I, a million things slarlcd going through my head. And I thought I wa,s gonna die. And, I was scared beoausc, I dtdn t know ii he was goima, I didn't know what he was gonna do. Hcjusl had sometlun* nl^ his hands and hc» lh& first words thai he said to me were, some oflhe firyl words he said is thiit he had a gun. And I thought lie was reaching for the gun. 1 thought he had fho gun in his Etand, in hiH right hand. And I thought lie had if enough to where all he had to do is just pull it out, point it al me, move his ii'tgger finger down on the trigger and let off rounds. And 1 had no other option than, to take out my fu'carm and, and 1 shot. Um I shot him.I don I remember the finsl couple shoLs. 1, believe I remember the last two shols. And I believe one of* the shots. went into Ins left yrm. Um, as I was shooting uh 1,1 kept watching him. And I, I remember smelling the gun smoke and {lie bright Hashes D-otn the muxxle. And then I heard, a couple pops uh from my tu'eEirm. (Jm and then my partner was oil the opposite side of the vehicle. Uh watch, looking in and I directed iny gimfirc down as best ay {could. Away from^ not trying (o put the liitte girl fi life nt jeopardy or the pas.songer or my partner because; they were, m thy Jmc ofniiy firo, Juronfmo Co. AUy Compliiint No; U6203738'79 Yoncx . Pygc;6ofl0 Kauscr was iiUeivicwcd by BCA invesligators at 1:10 AM on July 7, During that interview, Kauscrsaid the foilowing: Um I couldn't hear the convcrsaUon going on inside the vehicle. 1 could hear wliat my partner was saying. And, I, I don't rcmcjnber the entire conversation. 1 know my partner said doii't reach for it. And the passenger khula leaned on his right bull cheek add he put his Imnd on his right hip. I don*t know if he was reaching for y Hi'cami or WftIJcL [, I couldn't sec. I just saw thai he liac! his riglU hand on his hip. Like J said my pai-tncr said don'i reach for it. Ancl then t!)orcwere sliofs Hred," KiUKScr also said (i^U he did not sco Yiinc^ gun until he began shooting, Yanc/- gave no warning to Kauscr that Castile had a gun. When asked if he was surprised when Yancz began shooting, Kauser replied "absoiutcly." An nutopsy concluded that C^'iilc died ofcxsanguinalion due to multlpie gunshol wounds. '1'oxicoiogy testing showed that Caslile \v?is' positive for 'I'HC at the time oflhiy deatli. A bullet fired by Yancz passed Ihrongli tlw driver s seal and struck the rear sea( on the driver's side, Diamonci RcyuokV.s child, in her cw seat, was on the paysenger side of the reiir sent. Anolho!' buliel fired by Yancz ytruck llie armrest between Caslile and Reynoids> The robbery ofthe Super USA in Laucicrdalc remains unsolvcd, but subsequent investigation lias ruled out Csstile as rt suspect in that robbery, Video ofii robbery, committed in BIaine aHer the lime ofCastile's deatl^, shows a suspect whose physical features* resernblo the suspect from the Lauclcrdale robbery, and displaying a gun Mutt appears to be the same gun as Iho one used in Ihc Liuiderdalc robbery, The gun used in Ihc Laucierdale and Blaine robberies also appears (o be different than Castiic's gun, According to Jeffrey J. Noble, an expert on police procedure retained by ihe Ramsey County AUorncy's Office, the (otalily of the ch-yumstances indicate thai Yanez' use of deadly force against Castiie during the July 6 stop WH.S not necc^ary, wa.s objectively unfeationabie and wa.s' Jnconsiylenl with generally accepted police practices. In addition, under the s£imc oiroumstanccs, Ynnex\s discharge of his fn'earm seven times into a vehicle in very close proKimity to and Lowards Reynolds utKl her [biw-ycar-old dtiuglilef endangered Ibeir safety. Jcronimo Vmicz Piigc:7ofi0 Co. Atty Complaint No; 062037^79 Complainant reque.sls that Defendanl, subject to bnil o)' conclilions of release, be: (1) arrested or that olher lawi'ul Klcp;) be taken to obtain Defendants appearance in court; or (2) detained, iiah'cady In cuslody, puiKling furlher proceedings; and fliat said Oefcnclanl otherwise be denlt wilh according to law, COMPLAINANT'S NAM1?: PLAINAN.T^S SIGNATURE: Doug Henning ] declare under penalty ofjsprjury that cverylliing I have yUUed in tins documctit'^s true and correct Dated this /^ _ clay of-<^^//fe^ , 20 /^' ylgned in Ranzsey CoiifUy, Minncsola. Being authori/.ed lo prosecute the offenses charged^ I approve this complaint. Date: il^/S.^ _, 2016 P.ROS1^CJUTI^^ATTQRNEV\S SlCN/lTURE: Nam3?K'ici^^^iSl^ 345 Wabasha Street North, Suite 120 St. Paul, M^ 55102 651-266-3222/PS Attorney R.cgislralion If 299777 J'eronimo Yanez Page: 8 of 10 Co. Atty Complaint No: 0620373879 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 ;^ day of THEREFORE YOU,. THE ABOVE-NAMED DEFENDANT^ ARE HEREpY SUMMONED to appear on the I ^"T'1 jsb\K.^V)^C , 2016 at I'^O g.M. befoi-e the above-named court at 4^C L^^ ^-n-^<»<~ c-^^^\ C^^JC^r to answer tiiis complaint. IF YOU FAIL TO APPEAR in response to this SUMMONS, a WARRANT FOR YOUR ARREST shall be issued. D WARRANT D Execute in MN Only D Execute Nationwide D Execute in Sorder States To the Sheriff of the above-named county; or other person authorized to execute this warrant; I hereby order, in ffae name of the State of Minnesota, that the above-named Defendant be apprehended and arrested without delay and brought promptly before the abovenamed 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. H 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: ^ Th^s/complaint, duly subscribed and sworn to, is issued by the undersigned Judicial Officer this \ ^> day of ll^ H^-VWY. ^ 20 \\) . JUDICIAL OFFICER; NAME: TITLE: Sworn testimony has been given before the Judicial Officer by t^e following witnesses: COUNTY OF RAMSEY STATE OF MINNESOTA^ Clerk'^ Signature or File Stamp: STATE OF MINNESOTA Plaintiff, RETURN OF SERVICE / hereby Certify and Return that I have sei-ved a copy of this COMPLAINT upon the Defendant herein named. vs. JERONIMO YANEZ Signature of Authorized Service Agent: Defendant. JiTOiiimo Yiijnex Pftgy;9ofl0 Co. Ady Compluint No: 0620373879 RESPOND1GNT DATA / CHARGE SHEET- ATTACHMENT A ^™^B'^»?ll^Bf*"*nmmSgii^^^l3^WlltftIB^^ iI)i<;?NDANTNAME: Defendant alias namc(s); 'Defendant ta DOB(s): » nd dress: Sf ate ID; I7ingcrprint ID; FB) ID; 2016^33 S(. Pan! PD ID; OHcndorID; OTHER DEFENDANT / CASK rOENTlFlEKS: Fingerprinted? D No D Yes Htinctgun pennif? D No a Yes (issuing Agency; Loctition of violation; }V DRIVING OPrENSE: Driver's License Issuing Sditc; ; License P)alc Number; Issuing State; Acuidcnt Type: D No injuiy/nodamage check dii fhaf apply D Pvrsonni Injury Blood Alcohol Concuntmtion (BAG); D Propei-ty Dtttiittge D Pntotity Pngc: 10 of!0 .Iiii'onimo Yiiticx Co. Ally Complaint No: 0620373S79 CT NO 01-TENSt.i OAT1; STATUTE STATUTE TYPH NBR STATUTE Di.iSCRlP'HON OFFENSE LBVEL ri—'—I' MOC Q 0 c AGENCY ORT CN N13 R laJNCTlON I on oritbonf 609>205,(J) fuiy<>,2016 rliiiiiiloughtcr - 2iul Felony H50J3 )tigrcc- CuJpnblc kgli^cnce Crcnlin^ N Kurcaii ofCriminol Appreliunsion [BCA)ORI MNOCAOOOOCN- Jm'{;;ixonal)lc Ri.sk 2016-433 Clinrginfi 2 on ornboui 609.66,ln(n)(2) htty(),2(n6 )»ngct'ous Wcnpons- F'clony Wl i4A N nitiiifional Discharge of Burcnit ofO'hnimiI Apprehension [BCA)0}U MNBCAOOOOCN 'Irenrm Thnf ICiidnitgcrs .nf'ct^ 2U16-<133 Clinrtiini! 3 on ot-nbotif 609.66.1 ii(H)(2) Ftily 6,20)6 >fingcrous Wt-iipons- Pclony WI 1'IA ntenUoniil Djschnrgc of 'it'cfii'ni That Ktidrt«(J;cr.s' flfcty N Burcsiu ufCrtmlniil iVpprcEicnsion ;BCA)OiU " VINBCAOOOOCNSO 16-433 L.^luu'^inj