IN THE UNITED STATES DISTRICT COURT FOR THE

WESTERN DISTRICT OF MISSOURI

WESTERN DIVISION
UNITED STATES OF AMERICA,

Case No. ___________________________

Plaintiff,

COUNTS ONE AND TWO

18 U.S.C. 242 (Deprivation of Rights)
NMT: 10 Years
NMT: 3 years Supervised Release
NMT: $100,000 Fine
Class C Felony

Defendant.

COUNT THREE
18 U.S.C. 1519 (Obstruction of Justice)
NMT: 20 Years
NMT: 3 Years Supervised Release
NMT: $100,000 Fine
Class C Felony

v.
TIMOTHY RUNNELS,
[DOB: 07/26/1983]

COUNT FOUR
18 U.S.C. 1512(b)(3) (Obstruction of Justice)
NMT: 20 Years
NMT: 3 Years Supervised Release
NMT: $100,000 Fine
Class C Felony
$100 Mandatory Special Assessment for Each
Count
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

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,
2

Case 4:15-cr-00106-DW Document 1 Filed 03/26/15 Page 2 of 4

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.

3

Case 4:15-cr-00106-DW Document 1 Filed 03/26/15 Page 3 of 4

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___________________
DATE

____/s/ Helen A. Chaffin_____________

FOREPERSON OF THE GRAND JURY

___/s/ David Ketchmark___________

David Ketchmark
First Assistant United States Attorney

___/s/ Shan Patel_________________

Shan Patel
Trial Attorney
Civil Rights Division

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

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF MISSOURI
CRIMINAL CASE COVER SHEET
Place of Offense

Division of Filing

Matter to be Sealed

St. Joseph

Western

Central
Southwestern

Secret Indictment

Jackson
County and
elsewhere

Southern

Defendant Information
Defendant Name
Alias Name
Birthdate

Juvenile

Timothy Runnels
07/26/1983

Related Case Information

Yes

Superseding Indictment/Information

Yes
New Defendant
Prior Complaint Case Number, if any
Prior Target Letter Case Number, if any

No if yes, original case number

No

U.S. Attorney Information

AUSA David Ketchmark
Interpreter Needed
Yes
Language and/or dialect

No
Location Status
Arrest Date
Currently in Federal Custody
Currently in State Custody

Currently on Bond
U.S.C. Citations
Total # of Counts
4
Index Key/Code/Offense
Set
Level
1
18.242.F/9901/4

Writ Required

Yes

No

Warrant Required

Yes

No

Description of Offense Charged

Count(s)

Deprivation of Rights

1-2

18.1519.F/9992/4

Obstruction of Justice

18.1512B.F/9992/4

Obstruction of Justice

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