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STATEMENT OF CHARGES
NOW COMES Thomas Sheahan, Chief of Police of the Village of Oak Brook,
Illinois, and makes the following statement of charges against Officer Stephen Peterson,
of the Oak Brook Police Department. Police Chief Thomas Sheahan (hereinafter “Chief
Sheahan”) requests that the Board of Fire and Police Commissioners of the Village of
Oak Brook (hereinafter “Board”) set a hearing date on said charges and to take
appropriate action in accordance with the provisions of 65 ILCS 5/10-2.1-17 and the rules
and regulations of the Board of Fire and Police Commissioners of the Village of Oak
Brook.
Jurisdiction
1. Chief Sheahan at all times relevant to the bringing of these charges was
and is the duly appointed Chief of Police for the Village of Oak Brook.
appointed and qualified member of the Village of Oak Brook Police Department
(hereinafter “Department”).
3. At all times mentioned herein the Board was in existence and acting under
the authority of 65 ILCS 5/10-2.1-1, et seq., and its own Rules and Regulations.
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Statement of Facts
conversation with Stacy Peterson, the wife of Officer Peterson’s father, Drew Peterson, at
Drew and Stacy’s home. During this conversation, Stacy Peterson told Teresa Peterson
a.m., Officer Peterson received a telephone call at his home from Drew Peterson. During
that telephone call, Drew Peterson told Officer Peterson that Drew Peterson’s wife, Stacy
Peterson, had called him the night before and told him that she had left him for another
man, gone on vacation, and would deal with Drew Peterson when she got home. Drew
Peterson also told Officer Peterson during that telephone call that Stacy Peterson had
taken with her $25,000 and the title to the couple’s home.1
called Officer Peterson at home and stated that Stacy Peterson still had not returned home
and that Stacy’s family had filed a missing person report with the police.
Drew Peterson called Officer Peterson and told him that local news outlets were running
a news story about Stacy Peterson’s disappearance. During that same telephone call,
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Attached as Exhibit 1 is the Illinois State Police Report outlining the activities of Officer
Peterson immediately after the disappearance of Stacy Peterson. During his internal
interrogation Officer Peterson affirmed the accuracy of the facts in the Illinois State
Police Report, with one exception. Officer Peterson stated that he last saw Stacy
Peterson when he and his wife visited Drew and Stacy’s home on October 20, 2007, not
October 27, 2007, as indicated in an Illinois State Police report. This error was noted in a
subsequent Illinois State Police report.
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Drew Peterson told Officer Peterson that he was going to bring some of his guns to
8. At approximately 7:30 a.m. that same day, October 30, 2007, Drew
Peterson arrived at Officer Peterson’s home with three firearms contained in two separate
gun cases: a Colt AR-15 .223-caliber rifle, an Ithasa 12-gauge shotgun, and a Magnum
9. The AR-15 rifle had an 11.5 inch barrel, 4.5 inches shorter than the
standard barrel length of 16 inches on that model weapon used by the Oak Brook Police
Department.
10. Officer Peterson is familiar with the AR-15 model weapon because he
typically keeps such a weapon in an Oak Brook Police Department patrol car. Officer
Peterson is trained and qualified by the Department in the use of the AR-15 rifle.
11. When Drew Peterson arrived at Officer Peterson’s home with the three
guns, he told Officer Peterson that he knew the police would be looking at his house and
he did not want anything to happen to these particular guns because they were his
“favorites.” Drew Peterson further told Officer Peterson that the story of Stacy’s
12. After opening the two gun cases and looking at the weapons, Officer
Peterson concealed the weapons, contained in two separate gun cases, in the closet of a
13. Officer Peterson admitted in his internal interrogation that he did not
possess Drew Peterson’s guns for any purpose related to his law enforcement duties as a
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14. Officer Peterson did not alert any law enforcement authorities, including
the Illinois State Police or Chief Sheahan, or any other supervisor at the Oak Brook
Police Department, that he and Drew Peterson had concealed three guns, including an
AR-15 with an 11.5 inch barrel, in his home in order to prevent law enforcement from
discovering those guns during a search of Drew Peterson home in connection with Stacy
Peterson’s disappearance. Instead, Officer Peterson willingly concealed his father’s guns
15. Later that same day, October 30, 2007, Drew Peterson called Officer
16. At approximately 2:00 p.m. that day, October 30, 2007, Officer Peterson
arrived at Drew Peterson’s home where Drew Peterson was present with his two young
children. While Officer Peterson was present at Drew Peterson’s home, Drew Peterson
told Officer Peterson that he wanted Officer Peterson to take all four of his children in
case of his arrest. Drew Peterson gave Officer Peterson the telephone numbers of two
lawyers to call if he were arrested, as well as personal financial information regarding his
bank accounts, trust funds, etc. Drew Peterson also gave Officer Peterson three checks
totaling $236,800, including a $225,000 check drawn on a home equity line of credit
Drew Peterson had established on his home. The $225,000 check was dated October 29,
2007. Drew Peterson told Officer Peterson that he wanted Officer Peterson to have this
money to assist him in caring for Drew Peterson’s children and also so that no one else
could access it. Drew Peterson told Officer Peterson not to deposit the checks until Drew
Peterson instructed him to do so. After accepting these checks from Drew Peterson,
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17. After receiving checks totaling $236,800 from his father, Officer Peterson
still did not alert law enforcement authorities to the fact that he had concealed three of his
father’s guns, including an AR-15 with an 11.5 inch barrel, in his home in order to
prevent law enforcement from discovering those guns during a search of Drew Peterson’s
Stacy Peterson’s disappearance and it was widely speculated in the news media that
19. On November 1, 2007, the Illinois State Police executed a search warrant
disappearance. During this search, Drew Peterson called Officer Peterson and told him to
pick up Drew’s children at the home of Drew’s neighbor. After receiving this phone call
from Drew Peterson during the search of Drew’s home, Officer Peterson still did not alert
law enforcement authorities to the fact that he had concealed three of his father’s guns in
his home in order to prevent law enforcement from discovering them during their search
20. During the search of Drew Peterson’s home, members of the Illinois State
Police located four unloaded magazines for the AR-15 that Officer Peterson had
concealed in his home on October 30, 2007. A State’s Attorney Investigator asked Drew
Peterson where the AR-15 was located and Drew Peterson responded, “I knew you guys
21. Also on November 1, 2007, the day his father’s home was searched by the
Illinois State Police, Officer Peterson attempted to deposit the three checks Drew
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Peterson had given to him on October 30, 2007. The two checks for smaller amounts
were honored but the $225,000 check drawn on Drew Peterson’s home equity line of
credit was not honored because the line of credit had a maximum amount of $220,000.
Drew Peterson realized his mistake when he spoke with Officer Peterson on November 1,
2007, just after Officer Peterson attempted to deposit the check, and he corrected the
mistake shortly thereafter by providing Officer Peterson a second check for $215,000 on
the home equity line of credit. This second check cleared and the funds were deposited
in Officer Peterson’s personal checking account sometime during the week of November
4, 2007.
Peterson’s home, Drew drafted a will in which he bequeathed his entire estate to Officer
Peterson, signed the title of his motorcycle over to Officer Peterson, and ate lunch. At
approximately 1:45 p.m. that same day, Officer Peterson drove Drew Peterson back to
Drew’s home.
23. During the morning of November 2, 2007, Illinois State Police arrived at
Officer Peterson’s home to question Officer Peterson about the circumstances under
which he came to possess Drew Peterson’s guns. After answering the door for
investigators, Officer Peterson told them that Drew Peterson had given him the guns
because he expected to be arrested and did not want police to take those particular guns.
Officer Peterson then told the investigators that he did not want to discuss the matter any
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further at his home and he agreed to meet with investigators later that day at the
Q: You understood at some point that week that there was speculation
that your father was involved in the disappearance of Stacy
Peterson, correct?
A: I would say generally based on the fact that they had a search
warrant of his house it could have gone either way. It could have
been they suspected him or they wanted to see what she left
behind. I don’t know.
25. At approximately 3:10 p.m. that same day, November 2, 2007, Officer
Peterson was interviewed by Illinois State Police Special Agent Hardy and Sergeant
Lawson at the Bolingbrook Police Department while Officer Peterson was there turning
over his father’s three guns to the Illinois State Police. During the interview, Officer
Peterson admitted that he concealed three weapons for his father at his home on October
30, 2007, because Drew Peterson expected police to be looking at his house and Drew
did not want anything to happen to his “favorite” guns. Officer Peterson failed to
mention during this interview that on the same day he accepted the guns, October 30,
2007, his father had also given him $236,800 in checks which Officer Peterson had
26. Officer Peterson never disclosed to Chief Sheahan, or any other supervisor
at the Oak Brook Police Department, that this November 2, 2007, interview even
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occurred, much less the statements he made during that interview. Specifically, Officer
Peterson never disclosed to Chief Sheahan, or any other supervisor at the Oak Brook
Police Department, that he had concealed three of Drew Peterson’s guns in his home so
that they would not be discovered by law enforcement authorities during a search of
Drew Peterson’s home, that he had been interviewed by the Illinois State Police in
connection with Stacy Peterson’s disappearance, or that the Illinois State Police had taken
27. On November 29, 2007, Officer Peterson testified before a Will County
grand jury investigating Stacy Peterson’s disappearance. During his testimony, Officer
Peterson testified about concealing three of his father’s guns on October 30, 2007,
accepting $236,800 in checks from Drew Peterson on October 30, 2007, and Drew
Peterson’s visit to his home on November 2, 2007, during which he signed over the title
of his motorcycle to Officer Peterson, told Officer Peterson to raise his children if
anything happened to him, and drafted a will bequeathing his entire estate to Officer
Peterson.
28. On December 13, 2007, Officer Peterson again testified before a grand
jury investigating the disappearance of Stacy Peterson. During his testimony he again
recounted concealing Drew Peterson’s guns in his home and accepting a $220,000 check
29. In the spring of 2010, the Will County State’s Attorney’s Office
(hereinafter “SAO”) contacted the Department and informed the Department that Officer
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Peterson was under subpoena to testify at a hearing in the prosecution of Drew Peterson
for violating 720 ILCS 5/24-1(a)(7)(ii) (Unlawful Use of a Weapon) due to Drew’s
possession of the AR-15 rifle which had a barrel length less than the statutory minimum
of 16 inches.
30. This spring 2010 communication from the SAO led to an investigation
where Chief Sheahan learned the details of how Officer Peterson had concealed Drew
Peterson’s guns in his home during the week immediately following Stacy Peterson’s
disappearance and during the Illinois State Police search of Drew Peterson’s home, that
Officer Peterson never notified the Illinois State Police that he possessed these weapons
until they contacted him, that the Illinois State Police had taken possession of those guns
from Officer Peterson, and that one of the guns Officer Peterson had concealed was a
rifle with a barrel length less than 16 inches in violation of Illinois law.
31. Officer Peterson never notified Chief Sheahan, or any other supervisor at
the Department, that he had possessed the AR-15 rifle in the days following Stacy
Peterson’s disappearance, even after he was made aware that Drew Peterson was being
prosecuted by the SAO for possessing that same weapon and, therefore, that his own
32. On August 23, 2010, Officer Peterson testified before the Circuit Court of
Will County during a preliminary hearing in Drew Peterson’s prosecution for violating
720 ILCS 5/24-1(a)(7)(ii). During his testimony, Officer Peterson recounted for the
Court that on October 30, 2007, Drew Peterson brought three guns to his home enclosed
in two gun cases because those were Drew Peterson’s “favorite” guns and he did not
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want anything to happen to them. Officer Peterson further testified that he looked at and
33. On October 5, 2010, Officer Peterson was interrogated at the Oak Brook
34. During the interrogation, Officer Peterson was questioned about why he
failed to disclose during his November 2, 2007, interview by the Illinois State Police that
Drew Peterson had given him $236,800 in checks just three days prior, on October 30,
35. Officer Peterson also testified during the interrogation that he accepted his
father’s weapons on October 30, 2007, strictly in his personal capacity and that he had no
expectation or understanding that he would utilize those weapons in his capacity as a law
enforcement officer.
36. During the October 5, 2010, interrogation, Officer Peterson stated that he
has discussed the nature and substance of the Chief’s investigation of Officer Peterson’s
conduct with numerous family members and co-workers, including Drew Peterson, his
wife, mother, siblings, and friends including several fellow officers of the Oak Brook
Police Department , and a former member of the Oak Brook Police Department.
Department General Order prohibiting him from discussing an internal investigation with
any other person, that he does not believe he is excused from complying with that
General Order, and that he intentionally violated it because he “believe[s] that everybody
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38. During the interrogation, Officer Peterson also testified that the statements
he made during his interviews with the Illinois State Police, the recording of his
statements in Illinois State Police reports, and the transcripts of his testimony before the
grand jury in 2007 and the Circuit Court of Will County in 2010, are all accurate.
39. Officer Peterson has a long history of disciplinary issues as an Oak Brook
Police Officer. His disciplinary record exhibits a disregard for the Rules and Regulations
of the Department.
40. On April 15, 2005, Officer Peterson received a one day suspension
without pay for sending a mobile data terminal (“MDT”) message from a Department
patrol car to another patrol car inquiring about the physical appearance of a female
civilian.
41. On May 15, 2007, Officer Peterson received a one day suspension without
pay for failing to interact with a member of the public, specifically, a Village of Oak
Brook Trustee, in a manner consistent with the ordinary rules of good conduct and
42. On May 27, 2008, the Board imposed upon Officer Peterson an eight day
suspension, without pay, for violating Department rules and regulations when he drove a
Department patrol car to the Will County grand jury proceedings to testify on November
29, 2007, and December 13, 2007. With regard to the December 13, 2007, incident,
Officer Peterson had told his immediate supervisor that he was traveling “to court,” but
failed to disclose that the court was in Will County and that the proceedings related to
Officer Peterson’s personal business. The Board found that Officer Peterson’s conduct
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constituted “disingenuous avoidance of the truth prompted by [Officer Peterson’s]
personal agenda or an arrogant disregard for the Orders and Rules and Regulations of the
Police Department.” The eight day suspension was later reduced on administrative
review.
43. Less than six months later, on November 19, 2008, the Board imposed
upon Officer Peterson a twenty-five day suspension, without pay, for violating a
Department General Order and the Illinois Administrative Code when he made
The Board found that Officer Peterson had run multiple unauthorized LEADS inquiries
on his wife, his friend, his personal vehicle, the personal vehicles of other Oak Brook
police officers, the vehicle used by Deputy Chief Larson, and the vehicle used by the Oak
LEADS inquiries. The twenty-five day suspension was later reduced by agreement
between the Board and Officer Peterson after a ruling by the Circuit Court of DuPage
County remanded the penalty phase of the hearing back to the Board.
45. At all relevant times there was in effect an Illinois statute, 720 ILCS 5/31-
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institution employee of any authorized act within his official capacity
commits a Class A misdemeanor.
46. At all relevant times there was in effect within the Department Rule 1.14
Officers and members shall not interfere with cases being handled by
other officers and members of the Department or by any other
governmental agency unless: (a) Ordered to intervene by a superior
officer, or, (b) The intervening officer and member believes, based upon
information available to him that a manifest injustice would result from
failure to take immediate action.
47. At all relevant times there was in effect within the Department Rule 7.2
48. At all relevant times there was in effect within the Department Rule 7.3
No person has the right to violate the law. When an officer exceeds
his/her authority by unreasonable conduct, he/she violates the sanctity of
the law which he/she is sworn to uphold. All members shall respect and
uphold the law.
49. At all relevant times there was in effect within the Department Rule 14.11
Members shall conduct themselves in a manner that will foster the greatest
harmony and cooperation between each other and between divisions and
sections of the Department and other governmental departments and
agencies.
50. At all relevant times there was in effect within the Department Rule 14.25
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violations of federal, state, county or municipal laws and ordinances
relating to criminal matters or vice operations. Such reports shall be
submitted before the conclusion of the tour of duty during which the
member received the information or at the first opportunity in cases where
the information was received while the member was off duty.
51. At all relevant times there was in effect within the Department Rule 15.20
52. At all relevant times Article 18 of the Department Rules and Regulations
listed the actions that will subject a member to discipline. Those actions include:
18.39 “Any act which brings or tends to bring the individual or the
Department into disrepute.”
18.40 “Any other act or omission contrary to good order and discipline of
the department.”
53. Officer Peterson violated 720 ILCS 5/31-1(a) and Department Rules 7.2,
7.3, 14.11, 14.25, 15.20, 18.2, 18.19, 18.36, 18.39, and 18.40 when he failed to alert law
enforcement authorities, including the Oak Brook Police Department, that Drew Peterson
was taking steps to conceal his guns, when he concealed Drew Peterson’s guns in his
home with the specific intention of preventing law enforcement authorities from
discovering them during a search of Drew Peterson’s home, and when he failed to
disclose to law enforcement authorities, including the Department, that Drew Peterson
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had given him checks totaling $236,800 the day after Stacy Peterson was reported
missing.
Illinois law and the Department Rules and Regulations. As such, Officer Peterson’s
conduct constitutes some substantial shortcoming which renders his continuance and
employment in some way detrimental to the discipline and efficiency of the public
service and something which the law and sound public opinion recognize as good cause
56. At all relevant times there was in effect an Illinois statute, 720 ILCS 5/24-
57. Under 720 ILCS 5/24-2(c)(1), peace officers in the performance of their
official duties are exempted from the prohibitions of 720 ILCS 5/24(1)(a)(7)(ii).
58. At all relevant times there was in effect within the Department General
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All duty weapons and magazines will be issued by the Oak Brook Police
Department…. Off Duty firearms are limited to handguns and must be
approved by the Range Master.
59. At all relevant times there was in effect within the Department Rule 7.3
No person has the right to violate the law. When an officer exceeds
his/her authority by unreasonable conduct, he/she violates the sanctity of
the law which he/she is sworn to uphold. All members shall respect and
uphold the law.
60. At all relevant times there was in effect within the Department 15.20 that
states as follows:
61. At all relevant times Article 18 of the Department Rules and Regulations
listed the actions that will subject a member to discipline. Those actions include:
18.39 “Any act which brings or tends to bring the individual or the
Department into disrepute.”
18.40 “Any other act or omission contrary to good order and discipline of
the department.”
62. Officer Peterson violated 720 ILCS 5/24-1(a)(7)(ii), G.O. 96-0030, and
Department Rules 7.3, 15.20, 18.2, 18.36, 18.39, and 18.40 when he intentionally
concealed in his home a Colt AR-15 with a barrel 4.5 inches shorter than the statutory
minimum of 16 inches for no purpose related to his law enforcement duties, and then
failed to notify Chief Sheahan, or any other supervisor at the Oak Brook Police
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63. Officer Peterson also violated 720 ILCS 5/24-1(a)(7)(ii), G.O. 96-0030,
and Department Rules 7.3, 15.20, 18.2, 18.36, 18.39, and 18.40 when he failed to notify
Chief Sheahan, or any other supervisor at the Oak Brook Police Department, that he
possessed the Colt AR-15 in the days following Stacy Peterson’s disappearance, even
after he became aware that the Will County State’s Attorney’s Office was prosecuting
64. The exemption contained in 720 ILCS 5/24-2(c)(1) does not apply to
Peterson’s Colt AR-15 rifle for no purpose related to his law enforcement duties.
Illinois law and the Department Rules and Regulations. As such, Officer Peterson’s
conduct constitutes some substantial shortcoming which renders his continuance and
employment in some way detrimental to the discipline and efficiency of the public
service and something which the law and sound public opinion recognize as good cause
67. At all relevant times there was in effect within the Department General
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68. At all relevant times there was in effect within the Department Rule 6.6
69. At all relevant times there was in effect within the Department Rule 6.7
Members shall not make known to any person the contents of any
confidential directive or order which they receive, unless so required by
the nature of the order.
70. At all relevant times Article 18 of the Department Rules and Regulations
listed the actions that will subject a member to discipline. Those actions include:
71. Officer Peterson violated G.O. 96-0036, and Department Rules 6.6, 6.7,
18.30, and 18.36 when he, with full knowledge that he was violating G.O. 96-0036,
deliberately discussed the nature and substance of the Chief’s investigation of his conduct
with numerous family members and co-workers, including Drew Peterson, his wife,
mother, siblings, and friends including several fellow officers of the Oak Brook Police
Illinois law and the Department Rules and Regulations. As such, Officer Peterson’s
conduct constitutes some substantial shortcoming which renders his continuance and
employment in some way detrimental to the discipline and efficiency of the public
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service and something which the law and sound public opinion recognize as good cause
the Board of Fire and Police Commissioners of the Village of Oak Brook, Illinois, and
that the Board terminate Officer Stephen Peterson’s employment as a police officer of the
Village of Oak Brook, Illinois, in accordance with its authority under its own Rules and
Regulations and Section 10-2.1-17 of the Illinois Municipal Code, 65 ILCS 5/10-2.1-17.
____________________________________
Thomas Sheahan, Chief of Police
Village of Oak Brook
CHARLES E. HERVAS
KATHLEEN MCNAMARA
HERVAS, CONDON & BERSANI, P.C.
333 WEST PIERCE ROAD, STE. 195
ITASCA, IL 60143
630-773-4774
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