March 21, 2019
Via E-mail and First-Class Mail: robbp@ag.ks.gov
Office of the Attorney General/Biased Policing
120 SW 10th Avenue, Second Floor
Topeka, KS 66612
Re: Request for Investigation into Karle Robinson’s Complaint of
Racial Biased Policing by the Tonganoxie Police Department
On August 19, 2018, Tonganoxie Police Department (“TPD”) Officer
Brady Adams stopped and detained Karle Robinson while he was carrying a
television into his home. Officer Adams stated in a police report that he
suspected Mr. Robinson of committing a burglary. When Mr. Robinson
attempted to file a complaint outlining his concerns that he was detained due to
racial bias, TPD Chief Greg Lawson obstructed him from doing so, asking him
to meet instead. During the meeting, Chief Lawson dismissed Mr. Robinson’s
concerns explaining he supported Officer Adams’s decision to draw his weapon
and use handcuffs. TPD also subjected Mr. Robinson to a campaign of
surveillance and harassment following his August 19th detention that only
ceased when he publicly complained to the Kansas City Star. Each of these
incidents would be concerning had they been alleged independently. Together
they suggest a pervasive culture of racial bias and systemic process failure
within TPD. Accordingly, we request that the Kansas Office of the Attorney
General investigate TPD or refer this complaint to the Kansas Commission on

 Officers Standards and Training (CPOST) pursuant to K.S.A. §22-4606.
Factual Background
Karle Robinson is a 61-year old African American resident of
Tonganoxie. He is a Marine veteran and a native of Kansas. On July 13, 2018,
Mr. Robinson purchased his home at 1524 4th Street Tonganoxie, Kansas
66086. He gradually started moving in over the course of the next month while
he finalized the sale of his previous residence in Merriam.
Mr. Robinson rented a moving van to complete his move on the evening
of Saturday, August 18th. At 10:00 pm on August 18th, a Tonganoxie police
officer stopped Mr. Robinson while he was en route to his new home. The
officer ran Mr. Robinson’s license and gave him a warning citation. Mr.
Robinson arrived at his home at or around 12:00 am. To avoid disturbing his
neighbors, Mr. Robinson decided to not turn on the porchlight and instead
turned on the dome lights of the moving van for visibility. As Mr. Robinson
made trips in and out of the house, he saw Tonganoxie police Officer Brady
Adams observing him while he patrolled up and down Fourth Street. Over the
course of two hours, Mr. Robinson saw Officer Adams pass his house between
five and six times and they made eye contact on at least one occasion.
At or around 2:30am on August 19th, Mr. Robinson started to carry his
television inside. The television was the last item of the load of the moving
truck. As Mr. Robinson was going up the stairs of his home, Officer Adams

 pulled into his drive way, drew his weapon, and instructed Mr. Robinson to put
down the television. Mr. Robinson immediately complied with Officer Adams’s
directive and attempted to explain that he owned the house and was in the
process of finalizing his move. Mr. Robinson stated that he had paperwork
inside the house that would verify he was the owner. Rather than
accompanying Mr. Robinson inside the house to view the documentation,
Officer Adams handcuffed Mr. Robinson as he waited for backup. Officer
Pfannenstiel and Sergeant Collin Clair arrived on the scene. Officer Adams and
Sgt. Clair entered the residence and located the paperwork that Mr. Robinson
had told Officer Adams about five minutes earlier. Officer Adams and Sgt.
Clair returned outside and uncuffed Mr. Robinson. Officer Adams told Mr.
Robinson that he had to place him in handcuffs due to a recent string of
burglaries in the area. However, Officer Adams did not explain why he waited
approximately two hours before he became concerned that the Mr. Robinson
was committing a burglary.
Prior to his August 19th detention, Mr. Robinson had not heard of any
reported thefts or burglaries in his neighborhood. He had looked into crime
rates in the area when he was deciding whether to purchase the house in July
and there had not been any recorded reports. Thinking that the crimes Officer
Adams had cited were more recent, Mr. Robinson asked his neighbors if they
were aware of any burglaries in the neighborhood. His neighbors responded

 that the only incidents of theft they were aware of occurred across town.
TPD maintained a regular presence at or near Mr. Robinson’s home in
the weeks following his detention. Tonganoxie police squad cars parked
directly across the street at the water treatment center almost every evening.
They also frequently patrolled around his block. On the evening of August 21,
2018, a TPD officer followed Mr. Robinson from his home to the highway for
over 5 minutes.
On or about October 3, 2018, Mr. Robinson attempted to file an internal
affairs complaint with TPD about the August 19th incident and the subsequent
police presence he felt constituted surveillance. When Mr. Robinson arrived at
the police station and asked the receptionist to file a complaint, the receptionist
asked him to wait while she notified the Chief of Police, Greg Lawson. Instead
of allowing Mr. Robinson to file a written complaint, Chief Lawson proposed
that they meet instead. During the meeting, Chief Lawson insisted that he
approved of how Officer Adams handled Mr. Robinson’s August 19th
detention. Chief Lawson told Mr. Robinson that Officer Adams was justified in
drawing his weapon and applying restraints since he “feared for his life.” At no
point did Chief Lawson permit Mr. Robinson to submit a written complaint for
further review or investigation by TPD’s internal affairs unit. Chief Lawson
ended the meeting by telling Mr. Robinson that Officer Adams did not act with
racial bias or otherwise engage in improper conduct.

 Feeling that his complaint did not receive proper consideration, Mr.
Robinson contacted the Kansas City Star to publicize his concerns about the
detention. Joe Robertson, ‘Handcuffed on my own property’: Video shows
black homeowner questioned by Kan. police, KANSAS CITY STAR, Oct. 3,
2018, https://www.kansascity.com/news/local/article219422675.html.

It was

only after the Kansas City Star ran the story that TPD stopped surveilling Mr.
Robinson’s home.
Inconsistencies in Officer Adams’s Report
Mr. Robinson obtained a copy of Officer Adams’s police report and
bodycam footage from his August 19 detention in early October. See Exhibit 1Brady Report; Exhibit 2-Brady Body Camera Footage. Officer Adams’s report
contains a number of false statements and inaccuracies. First, Officer Adams
stated that he became suspicious that a burglary was underway when he
observed the porch light was on at 2:28 am. However, Officer Adams had
watched Mr. Robinson enter and exit his house multiple times in the two-hour
period prior to detaining him. Officer Adams alludes to the fact that he had seen
Mr. Robinson prior to making the stop stating “we’ve got someone moving
furniture in and out of the house.” See Exhibit 2 at :58. It is also worth noting
that, moving furniture into a house, conduct Officer Adams states he observed,
is not consistent with the elements of burglary as defined in K.S.A. § 21-5807
(a).

 Even if Officer Adams did not see Mr. Robinson while he was patrolling,
he would have observed the van and any lights that were on inside the house
long before 2:28 am. The lights had been on for at least two hours before they
became an actionable source of suspicion for Officer Adams. Therefore, the out
of the ordinary circumstance that purportedly sparked Officer Adams’s concern
could not have been the only reason he decided to stop Mr. Robinson.
Additionally, Officer Adams’s bodycam footage very clearly shows that
Mr. Robinson was going towards the stairs and into his home when the stop
was initiated. See Exhibit 2 at :41. This fact, in addition to the presence of a
rented moving van in the driveway, would suggest to a reasonable officer that a
move rather than a burglary was in progress.
Finally, contrary to Officer Adams’s report, there was no basis to believe
that the house was not occupied or still for sale. There was no “For Sale” real
estate sign on the property on August 19th nor had there been since July 13th
when Mr. Robinson closed on his house. Additionally, Mr. Robinson had
moved the majority of his things into the home in the month before he was
detained, leaving little reason for Officer Adams to have concluded that the
house was not occupied.
Had Chief Lawson permitted Mr. Robinson to file an internal affairs
complaint and conducted an investigation, TPD would have been aware of
these inconsistencies.

 Concerns of Biased Policing
Mr. Robinson believes his detention was motivated by his race rather
than a reasonable suspicion that he was committing a burglary. First, as
discussed in the proceeding section, many of the circumstances Officer Adams
states formed the basis for his suspicion that Mr. Robinson was committing a
burglary are disproved by the bodycam footage and are inconsistent with other
independently verifiable facts. In particular, Officer Adams’s decision to detain
Mr. Robinson at 2:28am despite observing his moving van and other indicia
that the house was occupied at or around 12:00am indicate that his stated
reasons for suspicion were pretextual.
Moreover, Officer Adams continued to suspect Mr. Robinson of criminal
conduct even as he uncovered additional evidence that corroborated his claims
that he owned the house. Once Officer Adams and Sgt. Clair observe the scene
inside the house, Officer Adams’s concedes “it does look like someone is
moving.” Id. at 6:20. They also find the paperwork under the counter, where
Mr. Robinson stated it would be located. Officer Adams responds to these facts
with continued suspicion, stating “I don’t know if that is his name or not, I am
going to bring it with me” and returns outside to verify the name on the
paperwork matches his license. Id. at 6:44.
Mr. Robinson also feels that the surveillance he was subjected to from
August 20 through October 4, was motivated by nothing other than TPD’s

 discomfort with his race. The fact that the surveillance stopped only when his
allegations of profiling were publicized in the Kansas City Star supports this
concern.
Finally, Chief Lawson’s intervention when Mr. Robinson tried to file a
written internal affairs complaint about his August 19th experience has
compounded his concerns that his detention and the subsequent surveillance he
experienced were motivated by improper considerations of race and bias. Even
if Chief Lawson had ultimately declined to investigate the matter, Mr. Robinson
wanted to make a formal written record detailing his experience and Chief
Lawson deprived him of that opportunity.
Conclusion
For the foregoing reasons, we request that the Office of the Attorney
General investigate this complaint, or, refer the matter to the Kansas
Commission on Peace Officers Standards and Training (CPOST).