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State Of Missouri,

Division Number: 11
Cause No. 1422-CR02722-01



Comes now the State of Missouri, by and through Assistant Circuit Attorney
Lauren C. Collins and informs the court of the following information which will give
the facts of the case, describe the defendant’s criminal history and recommend an
appropriate sentence for the charges of four counts of Unlawful Possession of a
Officer Joseph Busso received information from a confidential informant
that the defendant was in possession of weapons and there was drug trafficking
occurring at the defendant’s residence located at 1636 Belt Ave. in the
Wells/Goodfellow neighborhood. Officer Busso conducted an investigation into
the information that he received and on July 11, 2014, obtained a search warrant
for the defendant’s home, seen in the photo below.1 On that same day, Officer
Busso with other officers executed the search warrant.


All photos used in the text of the memo are attached in the Appendix in full size.


1636 Belt Ave. Photo taken by SLMPD

When Officer Busso entered the house, he observed the defendant run out of
a bedroom at the very front of the house. The defendant ran towards the kitchen,
which is located in the back of the house. As the defendant was running to the back
of the house he yelled out “Wen! It’s the police!” The defendant was alerting the
co-defendant, Wendell Miller that the police were in the home. Officer William
Wethington went into the room that the defendant ran out of in order to secure the
room. In that room, laying on top of the bed were two rifles and a 12 gauge

Photo taken by SLMPD

A further search of the defendant’s bedroom revealed a 9 mm. handgun in a dresser

and several personal items belonging to the defendant, including photos, an
Ameren bill, the defendant’s birth certificate, and his Missouri Department of
Corrections identification card.

Photos taken by SLMPD

Officers continued to search and secure the house and found Miller running from
the back bedroom towards the back door. Miller was taken into custody, and inside
of the bedroom he was seen running from were two handguns and over seven
grams of cocaine base, also known as crack cocaine.
After both the defendant and Miller were secured, they were interviewed.
The defendant told officers that he had the guns because he had to protect himself
even though he knew he could not legally possess a gun. Additionally he told
officers that anything found in Miller’s room belonged to Miller.
The defendant pled guilty on February 4, 2000, in the 22nd Judicial Circuit to
two separate offenses.
The first case was for the charges of Robbery in the First Degree, Assault in
the First Degree, Stealing Under $750, and Property Damage in the Second Degree
under cause number 2298104011-01. In that case, the victim told the police that
she was walking home from a friend’s house when the defendant approached her
and asked her for a date. The victim declined and asked the defendant to leave her
alone. The defendant became enraged and told her he would “Beat the sh*t out of
her” if she did not go out with him. The victim began to run away and that is when
the defendant threw a glass bottle at her, striking her in the head causing her to
have to get multiple staples. In another incident, the defendant and another man
approached a victim and using a gun demanded that the victim “give it up.” The
victim gave over jewelry fearing for his life. Shortly after the robbery, the


defendant was caught by police breaking into that same victim’s car. The
defendant caused damage to the victim’s car. Both victims were related to each
In the second case the defendant pled guilty to the charges of Murder in the
Second Degree and Armed Criminal Action under cause number 2298104022-01.
In that case the defendant was riding in a car with the victim when the victim and
the driver began to argue. The victim and driver got out of the car and began
fighting, at which time the defendant jumped into the fight to help the driver. The
defendant then got back into the car, this time in the driver seat, and drove the car
at the victim striking and killing him.
In both cases the defendant received 15 years in the Missouri Department of
Corrections. All time was served concurrently.
The defendant has a pending federal case arising from the same incident that lead
to charges in this case.
The defendant is a danger to the public. His history shows that he is
extremely violent and has no control over his temper. With that type of history the
defendant should not be allowed back on the streets where he will do nothing but
terrorize the St. Louis community. The defendant spent a total of 11 ½ years
incarcerated and during that time, he had 31 conduct violations. Some of those
conduct violations included, dangerous contraband, sexual misconduct and
possession of an intoxicating substance. The defendant continues to show that he
cannot follow laws and rules no matter where he is at. Even while on parole, the
defendant was revoked for a violation. Additionally, the defendant has been a
documented member of the Arlington Mob Gang. The defendant has numerous
gang tattoos on his body and posts photos holding up gang signs on his Facebook


Photo courtesy of Facebook

The defendant is a danger to the community and that is something that should not
and cannot be ignored given the alarming number of gun crimes in this city. The
number of guns and types of guns the defendant was in possession of is
frightening. There is no legitimate reason the defendant should be in possession of
firearms with the history that he has.
On March 23, 2015 the defendant was found guilty by a jury panel of 12 after a
trial on the four listed counts of unlawful possession of a firearm. During the trial
the court made the finding that the defendant is a prior and persistent offender.
This finding enhances the range of punishment in this case to the following:
Counts 1 -4: Unlawful Possession of a Firearm – 1 day to 15 years in the Missouri
Department of Corrections and/or a fine of up to $5,000
Wherefore the State of Missouri respectfully requests, that under the facts and
circumstances of this case, considering the history and character of the defendant,
and for the protection of the public, the Court impose a sentence of 15 years in the
Missouri department of corrections. The classification of the offense, defendant’s
prior criminal history and the protection of the citizens of the City of St. Louis make
this recommendation appropriate.
Respectfully Submitted,
/s/ Lauren C. Collins
Lauren C. Collins, 65843


Assistant Circuit
1114 Market Street
Room 401
St. Louis, MO 63101