10 a 12 13 as 16 W 18 20 2 22 23 2a 28 PILED? RAVALLI COUNTY ATTORNEY Bill Fulbright, County Attorney DEC $0 2613 Ravalli County Courthouse 205 Bedford Street, Suite C Hamilton, Montana 59840-2853 (406) 375-6750 Ravaili County, MT ustice of the Peace Attomeys for Plaintiff IN THE JUSTICE COURT OF RAVALLI COUNTY, STATE OF MONTANA BEFORE on. Wn BAWLEY JUSTICE OF THE PEACE STATE OF MONTANA, ) Cause No.: CR 2019- ) Plaintiff, ) Dept. No. 1/2 ) vs. ) ) FELONY COMPLAINT JOANN CAMPBELL, ) ) Defendant, ) ) State of Montana) 18s County of Ravalli —) Ravalli County Attorney Bill Fulbright, being first duly sworn, accuses JOANN, CAMPBELL of the following crimes, committed in Ravalli County, Montana: CHARGE 1 = DELIBERATE HOMICIDE, a Felony, in violation of § 45-5-102(1}(a), M.C.A On or about Decemiber 28, 2019, in Ravalli County, Montana, Defendant JOANN, CAMPBELL committed the offense of deliberate homicide by purposely or knowingly causing the death of another human being, Randall Robert Keller, jn violation of the above statute, DATED: December _22 , 2019. ea Bill Fulbright, County Attorney SUBSCRIBED AND SWORN to me this___ day of December, 2019, Tustice of the Peace FELONY COMPLAINT ‘ute v Joann Canpbet Page Lf}10 a 12 13 4 15 16 20 an 22, 24 25 RAVALLI COUNTY ATTORNEY Bill Fulbright, County Attorney Ravalli County Courthouse 205 Bedford Street, Suite C Hamilton, Montana 59840-2853 (406) 375-6750 Attorneys for Plaintiff IN THE JUSTICE COURT OF RAVALLI COUNTY, MONTANA BEFORE_H6n) Wi BAALEY _, sustice oF THE PEACE STATE OF MONTANA, ) ) Case No.; CR 2019. Plaintiff, ) ) Dept. Now 1/2 vs. ) ) AFFIDAVIT FOR PROBABLE CAUSE ‘THOMAS GWINN EDMONDS, ) i Defendant, ) ) STATE OF MONTANA) County of Ravalli ) Bill Fulbright, being first duly swom, deposes and says: Tam the County Attorney for Ravalli County, Montana, Ihave reviewed an ongoing investigation conducted by Hamilton Police Detective Bob Liercke and other officers of the Hamilton Police Department, and rely thereon in filing the accompanying felony complaint The investigation determined that Defendant is currently a 60-year-old female, whose spouse is the victim in this case. The deceased victim is identified as Randall Robert Keller, a 58-year-old male resident of Ravalli County, ‘The investigation further determined that on December 28, 2019, at 7:49 pan., Defendant called the Ravalli County 911 Center and reported that she had just shot and killed her husband. Defendant was reportedly crying and screaming during the 911 call, The scene of this incident AFFIDAVIT FOR PROBABLE CAUSE Sie v, Joann Campbell Page toa 2 13 ua 15 18 ag ‘was determined to be 600 Desta St, Hamilton, Ravelli County, Montana, Hamilton Police Officers and Ravalli County Sheriff Deputies arrived at the residence, gained entry, observed the victim on the floor with blood around him, and with EMT assistance confirmed that the vietim was deceased. The victim’s body was later transported to the Montana State Crime lab for autopsy by the State Medical Examiner’s office, The investigation determined that at approximately 7:15 p.m, that same evening, Defendant had walked into the Hamilton Police Department, saying she wanted to make a report, of prior, but ongoing physical abuse by the victim Keller. HPD Officer Honkala escorted Campbell into the HPD building and had her wait in the lobby so/hé Gould prepare the interview room, At the time, Officer Honkala observed that Defendant appeared to be intoxicated, A few minutes later, Officer Honkala went back into the lobby, only to discover that Defendant had left Later investigation determined that Defendant had left on foot, walking to nearby homes asking for a ride to the Desta residence. Defendant was interviewed at the Hamilton Police Department by Detective Liercke, Defendant reported that Keller has been both verbally and physically abusive toward her for the past two years, including assaulting her that morsiing when Keller hit Defendant on her right shoulder, Defendant stated that Keller was also'extremely verbally abusive toward her that moming, after which she had left the residence for the majority of the day, ultimately coming to the police department earlier in the evening to report the ongoing physical abuse by Keller, When asked, Defendant initially told Detective Liercke that she had left the police department prior to being interviewed by Officer Honkala because Officer Honkala “took too long” to assist her, Later in the interview, Defendant told the Detective that she left because she thought Keller would get arrested, that she would have to bail him out of jail, and that she already has paid ABPIDAVIT FOR PROBABLE CAUSE State: Jasna Cabell Page 20412 13 4 15 16 violence $20,000 in bail bond for Keller. Keller is the defendant in a pending case of dome: against Defendant, in which a sentencing hearing was pending, In her interview, Defendant further reported that when she returned home in the evening, after leaving the police department, she sat on her bed, which is in their living room. Defendant reported that approximately 10 to 15 minutes later, Keller entered the hallway adjacent to the living room and began yelling at Campbell, which she reported made her aftaid, Defendant reported that she retrieved a handgun from under the bed, struggled for a while “cocking it,” and then shot Keller while he was across the room in a “hallway” that leads out of the living room, Defendant reported that Keller immediately fell to the ground, and that she called 911 immediately after shooting Keller to report that she had shot and killed her husband. Law ‘enforcement officers who had first responded to the scene reported to Detective Liercke a ‘concern that Keller might have been deceased for a longer period of time because blood on the floor around the deceased appeared to have already started coagulating. ‘The officers also reported observing dried blood on the bedding that was on the bed on ‘which Defendant claimed she was sitting on during the shooting. When asked, Defendant reported that the blood would be Keller's blood, and that it was on the bedding because Keller ‘would pick his skin and bleed from it, Campbell advised she never approached Keller after the shooting, and that she threw the gun towards the foot of the bed. During a search of the home a Ruger 9mm semi-automatic handgun was found on the end of the bed, and one shell casing was recovered from a location consistent with the handgun having been discharged from the area of the bed described by Defendant. Detective Liercke observed during his contact with Defendant that Defendant appeared to] be intoxicated, and Defendant reported that she had consumed vodka during the afternoon, ABFIDAVIT FOR PROBABLE CAUSE Sil Joan Campbell Pago 3 0f4Blood samples were obtained from Defendant through execution of @ search warrant, which samples will be analyzed at the Montana State Crime Lab, On December 29, 2019, after Defendant was no longer apperently under the influence of alcohol, Detective Liercke met with Defendant at the Detention Center and interviewed Defendant a second time. During this second interview, consistent with the first interview, Defendant reported that prior to shooting him, Keller was yelling at her and verbally degrading her, but did not ever provide any details of Keller making any advances toward her or physically threatening her, despite being asked directly for any such facts, Defendant confirmed in both interviews that Keller was in the “hallway” when she shot him, Consistent with thet description, Keller's body was found by law enforcement officers on the floor of an entryway opening that connects the living room to a hallway and the kitchen DATED: December_32_, 2019. plo oe Bill Fulbright, County Attomey SUBSCRIBED AND SWORN to me this_ day of December, 2019, Justice of the Peace ABFIDAYET FOR PROBABLE CAUSE Ste Joann Capel Page dof