State of Minnesota County of Hennepin State of Minnesota, vs. Plaintiff, TYREL LAMAR PATTERSON DOB: 04/13/1989 1818 BRYANT AVE N Minneapolis, MN 55411 Defendant. Prosecutor File No. Court File No. District Court 4th Judicial District COMPLAINT Warrant 16A14916 27-CR-16-33298 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): 10/29/2016 Control #(ICR#): 16391901 Charge Description: That on or about 10/29/2016, in Minneapolis, Hennepin County, Minnesota, TYREL LAMAR PATTERSON, acting alone or intentionally aiding, advising, hiring, counseling or conspiring with others or otherwise procures the other(s) to commit the crime, caused the death of R.A., 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 Minneapolis Police Department, has investigated the facts and circumstances of this offense and believes the following establishes probable cause: On October 29, 2016, at approximately 5:00 a.m., Minneapolis Police Officers were dispatched to the intersection of 48th and Bryant Avenue North in Minneapolis, Hennepin County, Minnesota, on a shooting call. Upon arrival, officers located a vehicle just north of the intersection. Both the driver s side door and the front passenger door were open. Officers located a deceased male, later identified as R.A., in the driver s seat. The deceased had a gunshot wound to the head. An investigation into R.A. s murder was promptly started. Officers were able to learn that R.A. had likely been out that evening and early morning selling marijuana with a large amount of money in his possession. Officers did not find any marijuana in R.A. s vehicle and the amount of money on his person was not as described by family members. Officers were aware of a shooting earlier in the evening at the home of BRANDY LEE JAQUES, a Defendant herein, located at 4838 Bryant Avenue North. DERRICK ZECHARIAH SMITH, a Defendant herein, was charged with Assault in the Second Degree stemming from that incident. Defendants Jaques and Smith were recently charged in a homicide in Prior Lake along with TYREL LAMAR PATTERSON, Defendant herein. The Prior Lake murder involved the killing of a drug dealer during a robbery. As part of their investigation, officers were able to determine that R.A. was at a Super America gas station around 3:30 a.m. Video surveillance showed a young woman get into R.A. s vehicle. A friend of R.A. s indicated that R.A. came to her home sometime shortly after 3:30 a.m. bringing along a woman who matched the description of the woman on the video. Officers were able to identify the woman on the gas station video as AYAN ABDI WAHAB, a Defendant herein. In a statement given to the police, Defendant Wahab admitted that she was at the Super America and that she was there with Defendants Smith and Patterson. Defendant Wahab identified herself as well as the others on the surveillance video footage. Defendant Wahab reported that R.A. was attempting to sell marijuana and Defendant Smith started to speak to R.A. Defendant Wahab stated that R.A. had marijuana in a glass candy jar. Defendant Wahab stated that Defendant Smith told her to befriend R.A. and get more information about the drugs and money, so that Defendants Smith and Patterson could follow and eventually rob R.A. Defendant Wahab stated that she got into R.A. s vehicle and went with him to a house on Plymouth Avenue. Defendant Wahab reported that after leaving that home they drove over to Bryant Avenue North and parked on the street near Defendant Jaques home. Defendant Wahab stated that she exited the car and went into Defendant Jaques home where she further discussed with Defendant Jaques and Defendant Smith the plan to rob R.A. According to Defendant Wahab, Defendant Smith told her to call R.A., which she did. She discovered R.A. had not left, so she went back outside and got into his vehicle again. Defendant Wahab reported that she talked with R.A. for about five minutes before Defendant Patterson knocked on the vehicle window. Defendant Wahab stated that she exited the vehicle and walked back to Defendant Jaques home. According to Defendant Wahab, before she reached the home, she heard three gunshots. She reported that Defendants Smith and Jaques were no longer in the home when she entered. Defendant Wahab reported that she did not see who pulled the trigger, but had seen Defendant Smith with a gun earlier. Defendant Wahab further reported that after the shooting, she left with Defendant Patterson 2
and he had her throw a wrapped item she believe to be a handgun into the river. She also stated that during the car ride, Defendant Patterson was using her phone to speak to Defendant Smith and they were talking in code about the shooting. During the investigation, Officers were contacted by a known party hereinafter referred to as Witness A. Witness A is familiar with Defendant Jaques and had a conversation with Defendant Jaques during which Defendant Jaques stated the incident with R.A. was supposed to be a robbery. Defendant Jaques told Witness A that she received the okay to rob R.A. from Defendant Smith and that Defendant Smith gave her the gun. Defendant Jaques further told Witness A that it was arranged as a drug deal and that Defendant Jaques herself shot R.A. in the jaw. Defendant Jaques demonstrated for Witness A how the victim s jaw was dislocated from the shot, a fact known to be true by officers. The information about the victim s jaw was not made available to the public. Defendants Patterson and Jaques are in custody related to the Prior Lake Murder. Defendant Smith is in custody in Hennepin County on an Assault in the First Degree charge stemming from him firing shots at a police officer after fleeing from the Prior Lake scene. Defendant Wahab is not in custody. 3
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 James R Jensen Electronically Signed: Sergeant 350 S 5th St Minneapolis, MN 55415-1389 Badge: 3282 12/29/2016 08:17 AM Hennepin County, Minnesota Being authoriz ed to prosecute the offenses charged, I approve this complaint. Prosecuting A ttorney Dan Allard Electronically Signed: 300 S 6th St 12/28/2016 02:25 PM Minneapolis, MN 55487 (612) 348-5550 4
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) 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: December 29, 2016. Judicial Officer Mark Kappelhoff District Court Judge Electronically Signed: 12/29/2016 08:54 AM Sworn testimony has been given before the Judicial Officer by the following witnesses: COUNTY OF HENNEPIN STATE OF MINNESOTA State of Minnesota Plaintiff vs. TYREL LAMAR PATTERSON 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: 5