AO

9l (Rc, 08/09) CimrnalComplann

UNrrpo Srerps DtsrRrcr Counr

for the

Dist cl of Columbia
Uniled States of America

)
)
)

Larry Russell Dawson

)
)
)

Case: '1:16-mj-00271
Assigned To : Magistrate Judge G. Michael Harvey
Assrqn Date : 03/3'120'16
Desinption. Cnminal Complaint & Arrest

Def.ndantk)

CRIMINALCOMPLAINT
I. the complainant in this case, state that the followinB is true 10 the best ofmy knowledge and belief.
On or about lhe date(s)

of

District

in thc countl

[4a tch 28. 2416

of

Columbia

, the defendant(s)

of

in the

violated:

OJlense Description

Code Section

18 USC SS 111(aX1) & (b)

Assaulting, Resisting, or lmpeding Certain Offlcers or Employees with a

Dangerous Weapon

18 USC S$ 115(aX1XB) & (b)(1XB)

(iv)

Assaulting a Federal Law Enforcement Otficer with a Dangerous Weapon

This criminal complaint js based on these facts

See attached aflidavit

Conlinucd on the atlached shect.

V,Sur:e.l'aComplaihanl

-s

sighahtre

nR tve ra

Special

Prtnled name dnd tt)e

Sworn to bcfore m e and signed in my prcsence

Date:

03/31/2016
Judge s

CiD' and stale

rict of Columbia

., ,-_

]lleglstrate Judge G. Michqq!_Harvg/ _,

P,,nted,,aat nnd tttle

UNITED STATES DISTRICT COUIIT

DISTRTCT ()F COLUMBIA
ITNI'II.]I) S'IATES

()[

AMEI{:CA

case: 'l :16-mi-0027'l

Assigned To : Magistrate Judge G. Michael Harvey

Assion. Date 03/31/2016

DesJnption. Criminal Complaint & Arrest

LARRY RUSSELL DAWSON,

Defendant,

AFFIDAVIT IN SUPPORT O FC RIMINAL COMPLAINT AND ARREST WARRANT

Kathryn Rivera. an Otlicer with the United States Capitol Police. Washington. D C..
(hereinaller "your alfiant") being duly swom, deposes and states as lbllows:

l.

I am a Special Agent w'ith the Ljnited

Invcstigations Team.

States Capitol Police

("USCI'''). Criminal

am a Special Agent with the IJSCP, Criminal Investigations Section. I

have been a police otficer 1br approximately fifteen years and have been assigned to the Criminal

Invcstigations Section sincc 2011. t have invcstigatcd olltnscs involving the unlawtul usc or
possession

of

firearms. BB guns, and imitation firearms. and have been involved

in

the

investigation of incidents involving assauhs lvith a deadly u'eapon. assaulls on a police officer,
and aggravated assaults.

2.

This afiidavit is based, in part. upon my personai observations. inlbrmation

provided to me by other USCP officers, witnesses, review

of surveillance video. and other

information gathered during the course of this investigation. Since this atfidavit is being
submitted lbr the limited purpose of obtaining a criminal complaint and arrest warrant, I have

no1

included each and every fact known to me concerning this investigation. I have set lbnh onlv the
I'acts rvhich

believe are necessary to establish probable cause lbr a criminal complainl and

arrest warrant.

3.

'lhis affidavit is submilted in support of an application fbr a criminal complaint

and arrcst \\'arant charging LARRY RUSSELL DAWSON ("f)au'son'') w'ith Assaulting'
Resisting. or Impeding Clertain Ot'ficers or Employees with a Dangerous Weapon. in violation

l-itle

18. Llnited Srares Code Sg

ollicer wirh

lll(a)(l)

of

and (b). and Assaulting a Federal Law l]nforcement

a l)angerous Weapon, in violation

ol'f itle 18. United States Clode. $$ 115(aX1XB)

l)(B)(itl.

and (b)(

4.

As a result of my personal participation in this investigation, as well as through

inrcniews *'irh and analysis of reports submitted by other IJSCP officers. I am t'amiliar rvith all
aspecls

of this investigation. On the basis ol' this t'amiliarity. and on the basis of

other

information which I have reviewcd and determined to bc reliable, I allege the fbllowing tacts to
shor.v there is probable cause

to belicve that L)au'son assaulted, resisted, or impeded one or more

IISCP ot}icers with a dangerous \4'capon, in violation of Title 18. United States Code $$

lll(a)(l)

and (b), and a-ssaulted or thrcatcncd 10 assault one or more USCP otficers rvith

dangerous weapon.

in

of Title 18, lJnited

violation

Slates Code.

$$ ll5(a)(lXB)

and

(b)(l )(B)(iv).

5.
del'endant

Aviolationof Title

8. Unitcd Statcs Code, S$ I I l(a)( I ) and (b) occurs rvhen the

forcibly assaults, resists, opposes. impedes, intimidates, or intert'eres ',vith a USCP

ot'ficer while the ofllcer is engaged in or on accounl of the pcrformancc of officials duties. and in
the commission of such acl uses a dangerous *'eapon.

6.

A violation ol Title

18. United States Code,

$$ 115(a)(l)(B) and (b)(l)(BXiv)

occurs llhen the defendant assaults or threatens to assault a USCP ofllcer \4'ith the intent to
impede. intimidate.

or

intert-ere

with the offlcer while engaged in the performance of olhcial

duties, and where a dangerous \\'eapon was used during and in relation to thc offense.
2

7.

On Monday, March 28. 2016, at approximately 2:37 p.m.. an individual later

identilied as Dar.r'son entered thc north sccurity screening facility olthe Unitcd States Capitol

Visitor's Center ("CVC"). localed at

First Street, N.E.. in Washington. D.C. According to

CVC surveillance video. witness statements- and other investigative results. upon entering.
I)awson placed several personal ilcms in a bowl in preparation tbr going tfuough a metal
deteclor. Da$son then walked through one of four metal delectors at the CVC. and the dclecior
indicated the presence of metal at Dawson's waist level.

8.

USCP Oflicer Quincl Brisco directed Dalvson to pass back through the metal

dctector. The dctcctor ag{in indicated the presence of metai at Dau,son's waist level. Officer
Brisco then ushered Dawson through the melal detector. In response to the ot'tlceI's lequest.
I)ar.vson spread his

arms. of'hccr Brisco then scanned Dawsol with a hand-held metal deteclol,

u'hich indicated the prcsence of mclal in the area ofDawson's right waistband.

9.

Suddenly, l)awson reached into the area ol his waist w'ith his right hand, and

removed what appearcd

to be a black handgun. I)arvson also raised his lcfi hand bdwecn

himself and Ol'licer Brisco. ln rcsponse. Officer Brisco grabbed Dawson's leti upper arm. As
Darvson moved a*'ay

liom the officcr and to Darvson's right. the officer placed the hand-held

metal detector on Dawson's

torso. Dawson

seized the hand-held metal detector

Brisco and quickly moved pasl the ot'ticer, f'urther into the

tiom Oflicer

CVC. While moving. I)a\\,son threw

the hand-held metal detector onto the lloor.

10.

f-ew moments later. Dawson stopped rnoving

into the CVC, and tumed around

to face Ofllcer Brisco. Dawson held the gun in his right hand and pointed it at Ol'flcer Llrisco.
The ol-ficer movcd away'liom Dawson. and toward the metal detcctor equipment. while Dawson.

facing the ot'ficer u'ith the gun pointed at him. backed up inlo thc CVC area behind the detectors.

ll.

Ol'licer Brisco drew his weapon. pointed

it at Dawson. and continued to

back

awa1,.tiom Dawson and through the metal dclector gate. At about thal time. Oflicer Jerr-v Smith
started to move quickly around the metal detectol equipmcnt and into the CVC zrrea behind the

detectors, approaching Dawson on Dawson's

left.

During the encounter, Officer Smith gave

Dawson verbal commands to drop the gun and put his hands in the air, which Dau'son ignored.
Other oflicers gave Dawson similar verbal commands. u'hich Dawson ignored

12.

zrs

u'ell.

Dau'son now advanced torvard Oi'ficer Brisco, holding the gun in both hands and

pointing it at Officer Brisco. who continued to back away'from

wcapon drawn. quickly approached Dawson on Dawson's
moved toward the second metal detector on Dawson's

leli.

him. Oflicer Smith. with

his

Dawson. still holding the gun.

right. Ol'ficer Smith

then shot Dawson-

who continued to move toward the second detector. still aiming his gun at Oilicer Brisco. By
this time. Dawson had been pointing the gun at Ofliccr Brisco for approximalely

l0-l I

seconds.

Officer Smith shot Dawson again. and Dawson slumped onto the second detector's cxit roller
track. dropping his gun onto the rollers. Moments later, Dawson slunped onto the floor.

13.

'l'he entry doors into the screening lacility as well as the doors leading into the

CVC rvere locked to contain the threat. Dawson was apprehended, searched. rendered first aid

and transported 1o Medstar Washington Hospital Center. Metropolitan Police Department

Mobile Crime units recovered Dau'son's gun. a Daisy spring-loaded BB gun. from the rollers
where Dawson had dropped

it.

The gun resembled in color. shape. weight. and other outward

appearances a semi-automatic handgun.

14.

Under federal law, an imitalion gun, *,hen used in circumstances such as those

describcd herein. qualifics as a dangerous

u.s.

Eeapon.

.See. e.g.,

16 (1986) (unloaded handgun is dangerous weapon

srature):

(;i/ed

l4cLaughlin r. Liniled Stales.476

within me;uring of f'ederal bank robbery

States t'. Meclvecl,905 F.2d 935, 939-40

(6'r'Cir. 1990) (rcalistic to} gun used

during bank robbery is dangerous r.l.eapon or device satisfying sentencing enhancement since use

ol toy gun subjcctcd victinls

10 apprehension. required lar,'' entbrcement

to lbmlulate response

10

counter apparent threat to human life, and created Iikelihood that police response would include

(iome:,
deadly tbrce and incrcase risk to victims, bystanders, and perpetratols): Unile.l Slates v.
879 F.2d 256.259 (7th Cir. 1989) (functionality

of weapon not prerequisite to weapon's

dangerousness because, rcgardless ol' functionality, weapon instills f'ear and creates immediatc
danger that violcnt reaction

15.

u'ill

ensue).

'fhc surveillance video and witness

statements further show

that civilians.

including children, crouched against thc CVC's walls and behind the metal delector equipment

10

avoid gunfire. For example, aller Dawson dre\\ the gun. ollicers at the second detector. ri'ith
weapons drawn. used hand signals to usher a boy. wifh his hands over his ears and standing near
the seconcl detector, against the rvalland behind the detcctor cquipment. Also. a rvoman near the
second detecror grabbed a child by the hand and raced with the child to crouch behind officers
and detector equipment.

16.

I)awson is known to USCP. ln 2015, Dawson was denied entry to the House

office buildings alier attempting to bring a prohibited sign inside. On June 2, 2015, Dauson nas
stopped in reference to a breach of security. On October 22.2015, Dau'son disrupted Congress.

resisted of}icers. aliempted to tlee the scene, and was eventually arrested. In intcrvi$r,s with

IJSCP Threat Assessment Section and Intelligence agents, Da'\."'son expressed his interest in

meeting \1ith thcn-Speaker ofthe House.lohn Boehner regarding raising the minimum rvage and
asscficd that God had communicated rvith him in prayer and scripture lor him to demonstrate
regarding thc minimum wage.

17.

Afler his arrest on October 22, 2015. Dawson was charged in the Superior Courl

of the District ol Columbia with Assaulting, I(csisting or Interlering with a Police Officcr. in
violarion ol22D.C. Clode $ 405(b) (2001 ed.). and Disorderly and Disruptive Conduct on ljnited
States Capitol Grounds,
20 I

in violation ol l0 D.C. Codc $ 503.16(bX4) (2001 ed.) (Criminal No.

5-CMD-014629). On October 23,2015, as part ofbeing released fiom custody, Dawson was

issued an order. which he signed. to stay away from the "U.S. Capitol Building and Grounds to

include all Congressional Buildings and the areas bounded b-v 3'd St.

Nw / Constitution Ave'

NW/LouisianaAveNE/CStNlj/2'dSt.NE/CSt.SE/FirstSt.SE/washingtonAveSW./
lndependencc Ave SW / 3'd St.

18.

Sw Washington. DC.''

On December 8, 2015, tbllouing Dauson's failure to appear at a

appearance in the Superior Clourt criminal matler. the Court notilled Davvson that

scheduled

it had issued a

warrant for his arrest. In a lctter dated December 22.2015, Dawson replied:

I am Lany R. Dawson. a Ministcr and True Prophet of God. I have been called
chosen and sent unto You this da1. I arn not under the Larv! Romans 6:14 For sin
shall not dominion over you. For you are Not under the law, but under Grace!!! It
is a serious mistake to press lau'-obsen ance in the l'ace of repeated revelations
that the believer Of this age is nol under law as his rule of lii'e. 'lhercfore, I will
not comply with the court order, nor will I surrcnder myself unto your ollice. No
longer will I let myself be govemed by llesh and blood. but only by the Divine
Love ol God!!!!

CONCLUSION

19.

Based on the albremcntioncd lactual infbrmation.

I respectfullv submit that

there

is probablc causc to bclieve thar I.ARRY RUSSELL DAwSoN commirted violations of

6

1g

U.S.C. $$

lll(a)(l)

and (b) (Assaulting, Resisting, or Impeding Certain Officers or Emplo,vees

u,ith a Dangerous Weapon) and 18 U.S.C. $$ I ls(a)(lXB) ard (bXlXB)(iv) (Assaulting a

Federal Law Enforcemenl Officer with a Dangerous Weapon)'

Respectl'ully submitted.

Kathryn Rivera
Subscri

s!\om to belbre me this 3 l'r day' ol N4arch. 2016.

IY
HON. G. MICIIAEI,
UNITED STATES MAGISTRATF,

I'