State of Minnesota County of Hennepin State of Minnesota, vs. Plaintiff, SILAS TIMOTHY MCDOUGAL DOB: 11/10/1998 304 26th AVE N Minneapolis, MN 55411 Defendant. District Court 4th Judicial District Prosecutor File No. 18A07390 Court File No. 27-CR-18-16026 COMPLAINT Warrant The Complainant submits this complaint to the Court and states that there is probable cause to believe Defendant committed the following offense(s): COUNT I Charge: Murder - 2nd Degree - With Intent-Not Premeditated Minnesota Statute: 609.19.1(1), with reference to: 609.11.5(a), 609.05.1, 609.05.2, 609.19.1 Maximum Sentence: 40 YEARS Offense Level: Felony Offense Date (on or about): 05/17/2018 Control #(ICR#): 18001688 Charge Description: That on or about 5/17/2018, in Richfield, Hennepin County, Minnesota, SILAS TIMOTHY MCDOUGAL, acting alone or intentionally aiding, advising, hiring, counseling or conspiring with another or otherwise procures the other to commit the crime caused the death of J.W., a human being, with intent to effect the death of that person or another, but without premeditation, while using a firearm. Minimum Sentence: 3 YEARS 1
STATEMENT OF PROBABLE CAUSE Complainant, a licensed peace officer with the Richfield Police Department, has investigated the facts and circumstances of this offense and believes the following establishes probable cause: On May 17, 2018, Richfield Police Officers were dispatched to the parking lot of an apartment complex at 1318 E. 78th Street in Richfield, Hennepin County, Minnesota, on a suspicious vehicle call. Upon arrival, officers located an injured male inside the vehicle, who had been shot and was bleeding. The injured party was identified as J.W. J.W. was transferred to the hospital via ambulance. J.W. later died at the hospital as a result of the gunshot wound to the head. Officers did a quick search of the vehicle and located blood, a discharged cartridge casing, and items consistent with the sale of marijuana. A canvas of the neighborhood led to the discovery of a witness, hereinafter referred to as Witness A. Witness A reported hearing a gun shot and then seeing two suspects on the passenger side of the vehicle. Witness A reported that two male suspects ran westbound through the parking lot towards the garages. Another witness reported seeing four males near the dumpsters at Baymont Inn about 30 minutes before the shooting. Officers obtained surveillance video from the Baymont Inn. The video shows four males. Shortly after the 911 call, suspects 1 and 2 are observed jumping over the fence located between the hotel and the northwest side of the apartment complex. Moments later suspects 3 and 4 also jump the fence. Officers searched the area of the shooting and located three backpacks under a stairwell in one of the apartment buildings. Officers located a credit card application in the name of SILAS TIMOTHY MCDOUGAL, the defendant herein, in one of the backpacks. As part of the investigation, Crime Lab collected latent prints from the victim s vehicle. A palm print was recovered from the outside of the front passenger door window. The palm print was a match for the defendant. Investigation led to officers speaking with a known adult, Witness B. Witness B reported that on May 17, 2018, he met up with the defendant, along with Daniel Adams and T.B. Witness B reported they eventually headed toward the apartment complex in question. Witness B reported that the defendant said J.W. shorted him some marijuana and that he wanted to beat his ass. Witness B stated that once they arrived, he dropped his backpack and the defendant and T.B. did so as well. Witness B reported that he was with T.B. and they started walking towards the victim s vehicle and he saw the defendant in the front passenger seat and the victim in the driver s seat. Witness B stated that he heard a gunshot, saw the defendant exit the vehicle and then Witness B ran towards the Baymont Inn. According to Witness B, he heard others running behind him. Witness B reviewed the surveillance video and was able to identify himself, Adams, T.B. and the defendant as the individuals jumping the fence. Text messages, from May 17th, between the defendant and Witness B appear to discuss finding individuals to rob. The defendant is currently in custody on another matter. 2
SIGNATURES AND APPROVALS 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 declares under penalty of perjury that everything stated in this document is true and correct. Minn. Stat. 358.116; Minn. R. Crim. P. 2.01, subds. 1, 2. Complainant Brian Rogge Electronically Signed: Police Officer 6700 Portland Avenue S Richfield, MN 55423 Badge: 148 06/25/2018 06:59 AM Hennepin County, Minnesota Being authorized to prosecute the offenses charged, I approve this complaint. Prosecuting Attorney Dan Allard 300 S 6th St Minneapolis, MN 55487 (612) 348-5550 Electronically Signed: 06/22/2018 03:45 PM 3
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(s). SUMMONS THEREFORE YOU, THE DEFENDANT, ARE SUMMONED to appear on, at AM/PM before the above-named court at 300 S Sixth Street, Minneapolis, MN 55487 to answer this complaint. IF YOU FAIL TO APPEAR in response to this SUMMONS, a WARRANT FOR YOUR ARREST shall be issued. X WARRANT To the Sheriff of the above-named county; or other person authorized to execute this warrant: I order, in the name of the State of Minnesota, that the Defendant be apprehended and arrested without delay and brought promptly before the 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. Execute in MN Only X Execute Nationwide Execute in Border States ORDER OF DETENTION Since the Defendant is already in custody, I order, subject to bail or conditions of release, that the Defendant continue to be detained pending further proceedings. Bail: $1,000,000.00 Conditions of Release: No Contact with Co-Defendant(s); No Contact with Witnesses This complaint, duly subscribed and sworn to or signed under penalty of perjury, is issued by the undersigned Judicial Officer as of the following date: June 25, 2018. Judicial Officer Nelson Peralta Judge Electronically Signed: 06/25/2018 05:10 PM Sworn testimony has been given before the Judicial Officer by the following witnesses: COUNTY OF HENNEPIN STATE OF MINNESOTA State of Minnesota Plaintiff vs. SILAS TIMOTHY MCDOUGAL Defendant LAW ENFORCEMENT OFFICER RETURN OF SERVICE I hereby Certify and Return that I have served a copy of this Warrant upon the Defendant herein named. Signature of Authorized Service Agent: 4
Name: DOB: 11/10/1998 Address: Alias Names/DOB: SID: Height: Weight: Eye Color: Hair Color: Gender: Race: Fingerprints Required per Statute: DEFENDANT FACT SHEET SILAS TIMOTHY MCDOUGAL 304 26th AVE N Minneapolis, MN 55411 MALE Black Yes Fingerprint match to Criminal History Record: No Driver's License #: SILS Person ID #: 810185 SILS Tracking No. 3019873 Alcohol Concentration: 5
STATUTE AND OFFENSE GRID Cnt Nbr Statute Type Offense Date(s) Statute Nbrs and Descriptions Offense Level MOC GOC Controlling Agencies Case Numbers 1 Charge 5/17/2018 609.19.1(1) Murder - 2nd Degree - With Intent-Not Premeditated Modifier 5/17/2018 609.05.2 Liability for Crimes of Another-Reasonably Forseeable Penalty 5/17/2018 609.19.1 Murder - 2nd Degree Penalty 5/17/2018 609.11.5(a) Minimum Sentences of Imprisonment-Firearm Use or Possession Modifier 5/17/2018 609.05.1 Liability for Crimes of Another-Intentional Felony H2012 X MN0271800 18001688 No-Level H2012 X MN0271800 18001688 Felony H2012 X MN0271800 18001688 Felony H2012 X MN0271800 18001688 No-Level H2012 X MN0271800 18001688 6