Keown L Spencer #10788
Saran Coun Aterey
Surmpr Coan Courheuse
Welingon, KS 671
(620) 3267941
IN THE DISTRICT COURT OF SUMNER COUNTY, KANSAS,
THIRTIETH JUDICIAL DISTRICT
Criminal Department
STATE OF KANSAS PLAINTIFF
vs. CASE NO.:15 CR BI [g
JOSEPH DAVID RANDLE DEFENDANT
COMPLAINT
STATEOF KANSAS)
) ss:
COUNTY OF SUMNER)
1, Kerwin L. Spencer, County Attorney of Sumner County, Kansas, being duly sworn on
oath and upon information and belief, state that on or about NOVEMBER 24, 2015, at the
KANSAS STAR CASINO in Sumner County, and State of Kansas, one: JOSEPH DAVID
RANDLE (YOB: 1991) IRVING, TEXAS and did then
and there, knowingly, willfully, voluntarily and UNLAWFULLY,
COUNTI
did unlawfully, while inside the casino, did use fighting words or engage in noisy conduct
tending reasonable to arouse alarm, anger, or resentment in others, to-wit: Randle spit on the
casino floor after being warned not to do so and used abusive language alarming to Dealer
Darlene Mejia, Floor Supervisor Lisa Barnes, and Shift Manager James Scancella; and he knew
or should have known such acts would alarm, anger, or disturb others or provoke an assault or
other breach of the peace.
DISORDERLY CONDUCT
K.S.A. 21-6203, Class C MisdemeanorCOUNT 2
and did then and there unlawfully remain upon or in any land or structure, to-wit; the Kansas Star
Casino; knowing he was not authorized or privileged to do so and he did remain therein in
defiance of an order to leave such premises or property personally communicated to him by the
owner thereof or other authorized person, to-wit: Shift Supervisor James Scancella and Security
Supervisor Jeffrey Nickel determined that Randle would be ordered to leave the casino for 24
hours due to his use of sbusive language and spitting on the floor and notified Randle of this
decision and that it was nonnegotiable and mandatory that he leave immediately, but he refused
to leave immediately and continued to use abusive language and delay his departure and had to
be escorted outside to compe! his departure and then moved to reenter the casino, but was
stopped by KRGC agents.
CRIMINAL TRESPASS
K.S.A, 21-5808, Class B Nonperson Misdemeanor
COUNT3
and did thereafter just outside the casino doors, did unlawfully use fighting words or engage in
noisy conduct tending reasonably to arouse alarm, anger, or resentment in others and he knew of
should have known such acts would alarm, anger, or disturb others or provoke an assault or other
breach of the peace, to-wit: when Randle was outside, but refusing to leave, Agent Daniels
approached and showed his badge, Randle used profanity to threaten Agent Daniels with bodily
harm amounting to fighting words
DISORDERLY CONDUCT
K.S.A. 21-6203, Class C Misdemeanor
COUNT 4
and did then and there unlawfully knowingly obstruct, resist, or oppose a law enforcement
officer, to-wit: KRGC Agents Daniels and Good; in the discharge of an official duty, byphysically resisting arrest after threatening Agent Daniels and then ran from Daniels when
advised he was under arrest and when caught, physically resisted being handcuffed.
INTERFERENCE WITH LAW ENFORCEMENT
KS.A. 21-5904(a)(3), Class A Nonperson Misdemeanor
WITNESSES: MARIE CRAVEN, COCKTAIL SERVER
FLOOR SUPERVISOR BRANDY BEACH
FLOOR SUPERVISER LISA BARNES
DARLENE MEJIA, DEALER
MANOLY MOUNKHATY, BEVERAGE SERVER
SECURITY OFFICER CHRISTOPHER PIACENZA
SECURITY AGENT BRIAN BREWER
KRGC AGENT TYLER LEWELLEN
KRGC AGENT CEDRICK DANIELS
KRGC AGENT BRAD GOOD
MPD OFFICER JEROME CARTER
MPD SERGEANT SCHMIDT
SECURITY MANAGER MARK WARD
SHIFT MANAGER JAMES SCANCELLA
SECURITY SUPERVISOR JEFF NICKEL
surveillnce Obstet Oryin Crow npeisr
Contrary to the form of the statutes in such cases made and provided, and against the peace and
dignity of the State of Kansas.
Sumner County Attomey
Sudscribed and Sworn to before me this 3 9 day of NOVEMBER, 2015,
ALAMD.
JUDGE OF THE DISTRICT COURT