You are on page 1of 7

INDY DRUG PAGE 021'10

IN THE CIRCUIT COURT


OF JACKSON COUNTY, MISSOURI
AT INDEPENDENCE

COMPLAINT
STATE OF MISSQ'U'H

Randy W, La.nde
43 5 W. Pnrrm~er
Independence, MO 64050
DOB: 02/19/1965; RaeeISex: W/M;
IV
Defendant.

-
Count I. Forcible Rape child less than 12 years o f age (11005030)

The Pros~cutingAttorney o f th.e County of Jackson, State o f Missouri, upon information .

and belief, charges that the defendant, Randy W. Lande, in violation of Section 566.030,
RSMo, committed the felony o f fcrcib1,e rape, punishable upon canviction under Section
566.030, RSMo, and subject to lifetime supemision under Sectjan 217.735, RSMo, in' that
bctween Fcbmary 2,20 11 and February 3,20 1I., in the County of Jackson, State o f Missouri, the
defendant bowingly had sexual intercourse wit13 L.C., (DOB: 06/26/2002), a child less than
twelve years o f age, by thc use of forcible compulsion.

-
Count 11. Forcible sodomy child less than 12 years of a p (110821,40)

The Prose~utingAttorney of the County of Sackson, State of Missouri, upon information


and bdjef, ch,arges that the defenddant,Randy W. Laade, in vjolation aE Section 566.060,
RSMo, committ~edthe felony of forcible sodomy, punishable upon conviction under Section
566.060, RSMo, and subject to lifetime supervi,si,onund,er Section 217.735, RSMo, in that
between February 2,201 1 and February 3,20 11, in the County o f Jachson, State of Missouri, the
INDY DRUG PAGE 03/10

defendant for the purpose of arousing or gratifying the sexual desire of defendant had d-te
sexual intercourse wi,th LC.,(DOE: 06/26/2002, a ohild less than twelve years of age, by
putting; his penis in L.C.'s anus by the use of forcible campulsibn.

Count 111. Forcible sodomy - child less than 12 years o f age (12082140)

Tlte ,Prosecutin,gAttorney of the County of Jackson, State o f Missouri, upon infomation


and belief, cl~arpesthat the d,cfendant, Randy WwLand4 i,n violation of Secti,on 566.060,
RSMo, committed the felony of forcible sodamy, punishable ulpn conviction under Section
566.060, RSMo, and subject to lifetime supervision under Section 217.735, RSMo, in that
between February 2,20 11 and Pebrua~y3, 201 I,, j,a the County a f Ja~ksbn,State of Missouri, the
defendant fur the purpose of arousing or gratifying the sexual dcsirc of dcfcnclant had dcviaie
sexu.al intercourse with L.C.,@OB: 06/26/2002), a child less than twelve years o f age, by
putting hi,spenis in L. C .'s ~nouthby the use of forcible compulsion.

Cmlat XV. Forcible sodl,omy- child less than 12 years o f age (11 082140)

Tl9.eProsecuting Attomey o f the County o f Jackson, State o f Missouri, upon information


and belief, charges that the dcfmdant, Randy W. Laade, in violation of Section 566.060,
1
RSMa, committed the felony of forcible sodomy, punishable upon convictian mder Section
566.060, RSMo, and subject to lifetime supervision under Section 217.735, RSMo, in that
between February 2,201 1 and Fcbruary 3,201 1, in the County o f Jackson, State of Missouri, the
def~ndmtfor the purpose o f arousing or gratifying the sexual desire of defendant had deviate
sexual, intercourse with L.C., @OB: 06/26/2002), n child less tban twelve years of age, by
putting his mouth on L.C.'svagina by the use of forciblc compulsion.

Count V. Forcible sodomy - chlld less than 12 years of age (11082140)

The Pmse~u~ting Attorney of the County of Jackson, State of Missouri, upon information
and belicq charges that the defenddant,Raody W. Lande, ~ J Ivi,ol,aticnof Scctiw 566.060,
RSMo, co&#ed the felony of ForcibIe sodomy, punishable upon conviction under Section
566.060, RSMa, and subject to l i f e t h e supervision under S e c t i . ~217.735,
~~ RSMo, in that
between Febmruy 2,201 1 and February 3,201 1, in rhe County of Jackson, State af Mjssouri, the
defendant fox tbe purpose of arousing or gratifying the sexu.a.1desire of defendant had deviate
scxual intercoutse with LC., @OB: 06/26/2002), a ~Mldless than twelve years of age, by
putting his finger in L.C.'svagiia by the use of forcible compuIsj,on.

Count VI. Forcible sodomy - child less than 12 years of age (11082140)

The Prosecuting Attorney of the County of Jackson, State o f Missouri, upon idamation
an,d belief, charges tl~atthe defendant, Randy W. Lande, in vi,olation of Section 566.060,
WMo, committed the felony o f fbrciblc sodomy, punisl~ableupon conviction under Section
566.060, RSMo, and subjcct to lifefime supenision und,cr Secri.an 217.735, RSMo, in that
02/04/2011 11: 38 8814595 :CNDY DRUG PAGE 04/10

belwee1-1February 2,2011 and February 3,20 11, in the County o f Jackson,State of Missouri, the
defendant f ~ the
r purpose of arousing or gratifying the sexual desire of defendant bad deviate
sexual i~itercoursewith L.C., (DOB:06/26/2002), a child bss than twelve years of age, by
putting his finger in L.C.'s anus by the use of forcible compulsion.

-
Count VII. Kidnapping Facilitating a Felony (16020030)

The Prosecuting Attorney of the County of Jackson, State af Mis,~ouri,upon infmation


Randy W. Lande, in violation of Section 565.110,
and beli,ef, charges that the defe~~dant,
RSMo, committed the class B Eelony of kidnapping, punishable upon con,viction under Section
558.011., RSMo, in that between February 2 , 2011 and Febnorry 3, 2011, the defendant
unlnwfully removed L.C. witl~o~zt her conrent from a bedroom at 620 N. Pleaant, the p l a ~ e
where she was found by the defmd,ant, for the purpose of facilitating tb,e ~o~nmission
of th,e
fe1,on.yo f the forcible sodomy o f L.C.

The facts that farm the basis for this information m,dbelj,efare contained in the attachsd
statement(s) o f facts, made a part hercof and submitted as a basis upon which this court may find
the existence o f probable cause.

prays that an anest warrant be issued as provid,ed by


m e r e f m e , the Prosecuting Att0rn.e~
1.aw.
INDV DRUG PAGE 06/10

PROBABLE CAUSE STATEMENT FORM

-
Date: 02-03-11

I, Steven, Schmidli,,a Detective with the Independence Police Depa,rtmeat,knowing that false
statements on this L r m are punisha-bleby law, state that the facts contained herein are true.

1. I have probable cause to believe that on 02-03-10 between 0600 hours and 1050 hours, at
620 N. Pleasant, Xndependencc, Jackson County, Missouri, Randy W* land^, W M , 02-19-
65, comEommitted one or more criminal offense(s).

2. The facts supporting this belief are as follows:


On 02-03- 1J, at appr&imarely 1038 l ~ o mOfficer
, Yeager m d Officer Barker wcre dispatched
.
to 620 N. Pleasant on a reported sex offcnse with the suspect still at the residence. Officer Pilant
was closer to the residence than Offioer Barker so he advised dispatch fiat he would be en
route, and he responded to the area. As Officer Pi1,antwas entering the area, dispatch advised a
white male suspect wearing a brown jacket was possibly leaving the area in a 4-d,oor maroan
car. Officer Filant was just south ofthe resj,denceon Pleasant and observed no vehide leave.
Officer Pilant quickly circled the block, checking for the vehicle while waiting for other officers
to arrive. ~ f f i c ePilant
r observed no vehicle matching that description.

Officer Yeagcr ,entnteredthe area and Oficw PiIant responded to the residence with hhe Officer
Yeager knocked on the front door. An adult white female answered the door and standing
behind 11er was an adult white male. Officer Yeager asked the white female if here was a
problem,and she stated tnat "she was in the bedroom." The female then led the officers to a teas .
bedroom of the house on the noflhwest side of the residence, and. on the bed was a juvenile
:Female, Officer Yeager noticed was tkat the juvenile female had blood on her .ershirt,-her pmts,
md up and down her arms and legs. She was wearing a white long sleeve T-shirt and d u k
colored shorts. Officer Yeagcr also noticed that she was 1ying on a mattress without any sheets.
The maattresswas either a full size or queen sizc. Thcre was bl.ood On the mattress. From the
blood tlmt Officer Yeager observed, it appeared to be blood that was fresb an,d it appearcd to
have dots,init. The juvenile was obviously upset and was shaking. She also appeared to be
having difficulty brda.thing. Officer Venger asked the juvenile female what ha,dhappened aad
she told Officer Yeager tlmt he had tried to "hwap" her. Officer Yeager asked her Gh.0 did this
ta her and she to1.d Officer Yeager "Randy-"

The victim, who was identified as LC(8 years old), WE, 06-26-02 wasn't able to provid,emuch
innformationbecau,scshe was hyperventilating and seemed to be going into convulsions. LC did,
tell Offi,cer Yeager that be lnad done tbie to her a.11 night, and chat it started in the other bedtoom
and he moved her to the bedroom that we found her in. LC also told Officer Yeager that ha had
given her some whiskey. LC said.that she was sore Erom hi.1~ putting his hands mound h,erneck
and strm,gl,in,ghe?:, and sai,dthat she thinks that she did pass out from'bim d,oingthis. From
tdking with Linda she told OfG,cerYeager that he was "humping" her and that he put it in her
moutll and aTso her butt.
INDY DRUG PAGE 07/10

Fire and AMR personnel arrived on sccne and bated the juvenile victi~im.The victim was latcr
transported to Children's Mercy by AMR. Officer Yeagm followed the ambulance to
Children' s Mercy T3ospital Emergency room and then stayed in the rooln.while tb,ehospital
personnel attended to LC. At the hospital.,LC was unddrc:ssedand Oficer Yeagcr observed that
LC was covered in blood all over her pelvic region and was still bleeding heavily. She was
soaking through several pads while Officer Yeager was back in the room with her. LC was
scdated at the b,ospitaland I did not ask my fiutIb.er questions. Officer Yea.gerwaited at t11e
Emergency room. until Det. Nunez arrived on scene. Officer Yeager was told that LC was going
to be taken to t h operatin,g
~ room for surgery.

Officer Tilley and Officer Jarnagin arrived on scene and assisted Officer Pi,lantin secu.ringthe
crime scene. Officer Pilant cantactedacting Sgt. Pope, who t l ~ erequested
i~ that the lab and
detectives respond.' Officers Jaynagin and Ti,lleycontacted the parties on scene and relayed
suspect informatiou to officers who were in the area searching for the suspect and vehicle.

Officer Pilant obscnod the fo'ollowingitems of evidtentiaryvalue inside thc residence:


a. A bunk bed. in a middle bedroam 012 the south side of 1:13.e residence. Officer
Pilmt observed what appeared to be blood on the sheets on the lower bed of the .
bunk bed.
b. Officer Pilant observed what appeared to be blood on,and around the toi,letinside
a bathroom in,the middle of the hallway an the north side of t11.e residence.
c; Officer Pilaat observed what appeared.to be blood on the bed and rhe side of the
bed in the back northwest bedroom,.
d. Officer Pilant observed blood to be on a chair which was against the wall in the
living room.
e. Offi,cerPilant also observed what appeared to be a blood droplet on the floor in
front o f the chai,~.

After AMR had transported the juvenile LC, Oficer Pilant contacted ' .LY
wl~oadvj,sedthe following: Mr, Id his wife, ., were sl.eepi.ng
o n the co~zchin the living room ofthe residence. Ms. woke Mr. md
advi.sed him she heard what she believed was so~neonecrying. g o t up and,
began looki,ngaround the residence for the party that was crying. Mr. said t11at LC
spent the night with LB,WF 08-03-06, and DP, W/F 12-09-991after a. birth.day party at the
residence the previous night. The three juveniles had been sleeping in a middle bedroom on the
south sid.e of t h resi.dence.
~ Mr. Icould not locate LC. He attempted to check in h te
back northwest bcdrom for her, but was advised by Ran,d,yW.Lmde t11,atLCwas not. in that
bed,room. Randy W. Lande is friends with - , who owns the residence, and
bad taken her to work earlier in the day using l~,ervehicle,a burgund,y,2001, Oldsmobile, Alero.
Mr. 1 . responded to the basement, where he contacted, I about the crying.
No one in the basement was crying and they believed the crying was coim,ingfrom upstairs.

Mr, m.dMr, : espondcd to the back northwest bed,room, where thcy located
LC lying on the bed crying. Mr pipickedLC up and brought her to the living roam. In
thc living rQorn,they all noticed that LC was bleeding from her midsection. They a>entook LC
back t o the bedroom. Mr. Iresponded ro the basement, where he called 911. Randy

Page 2 of 5
INDY DRUG PAGE 08/10

Lande becamc w r y upset and stated ,that11ewas '%red o f this shit". He responded to tile back
nodliwest bedroom and retrieved what appeared to be sh,eets from the bed. He responded to zhe
front door, where he retrieved a pack of beer and then left the rssid,encein the marooa Alero.

Lab technicians Brent McHenry and Kevin Phillips arrived and began processing the scene.
Prior to Officer Pilant contacting my other partj,esin regard to a statement, Det. Lipps and Db.
Schmidli arrived.on scene. Officer Pilant assisted in securing the s c w and
~ transporting
witnesses to headquarters for their statements.

ARer the call was origjnally dispatched, officer Nlwood responded to the arca, and officers on
scene advised the suspect had possibly left in a maroon Oldsmobile Aurora. ORGcer Allwood
continued with the area chcck for the suspect vehicle when Oficw Fowler advised b,e had
located a vehicle matching the suspect vehicle description. The vel~iclewas later determined to
be a 2001 Oldsmobile Aurora with a public VTN of 1G3GS64C014182096. The vehicle also
displayed an expi,redKansas temporary ag on the rear li,censeplate bracket. Officer Fowler
advised hc was traveling southbound on Main from B. 24 Hi.gl~way.Officer Allwood was able
to pull in behind Offioer Fowler near Main and College where they then attempted to conduct a
traffic stop.

Mtcr activating emergency lights the Auiora continued for a short distance on Main and then
turned westbound onto Fsrmer. The driver thm stopped, but appear& to be moving something
arourrd in the front seat. A felony vehicle stop was initiated y d the driver was removed from
the vehicle and immediately placcd into 11ndcu;ffs. Officer Allwood asked the driver for his
name and hc advised Randy Land,e,which was the suspect in the sex offense.

While placing Mr. Lmde into hmd.cuffs, Officer All.wood noticed a sn~alIanlount of what
appeared to be bl,oadjust above l~iisupper lip (left side). Officer Al~lwoodcould not
immediately determine if there was an injury or if the substance camc from somewhere clse.
Officer Al1,woodalso noticed a substance around several of his finger nails which also bad the
nppearancc of dried blood. Believing that this sulxta~,cnce could be of evidential vdue, and th,atit
could be easily lost, Officer Allwood immediately notified Capt. Tt~ompsonwl~o],ladresponded
to the scene. T1.l.ecrime lab was ordered. Officer Allwood remained with. Mr. Lmda until, t11e
arrival o f Crime Scene Investigator Perry who Officer AUwood assisted with tbe gathering of
the evidence. Officer AILlwood also reported seeing white, rnulti colored, quilt lj,ke blanket and
shcetts wadded up i,n the backseat af the veh.iele,along with other clothing that appeared to be
men's clothing. Officer Allwood also obscrved a 20 pack of Budweiser battle bier siaing in the
vebi cle, and reported.that Lande was dridcing a be w at fie time he was stopped.

A police tow was ordered for Mr. Lande's vehicle a,ndit was secured with evidence tape. At
this point, the contmnts of the vehicle were not inventoried or tampered wi,tl~.The veh,i.clewas
towed to the Independence Police Department's Penniston 13uilding located at 14609 E. Trwna~~
Road, Tndependwcc, Jackson County, Missouri where it was secured in the gwagc.

11 shau1.d also be noted tlwt during the arrest of Mr. Lande, he did no1 seem to be surprised by
the arrest. He did not ask any questions about why he was being stopped or m o w d from the
vehiclc at gun point. The only thing he really asked about was if he could have "One last
mlde .\Nas then
Figpimi
HSe ''J ~ E 1,W
ufir:d. nm
S ~ Q Vbr haye in hd,cuffs
I ~ rimailled *7mn'""l a sra?Gbwanmi
Tanso ni d
the p D Drrmti,on ~ " 3 on ls
bi obtsj,ned recover t \ ~
P V T.mda+
02-0in.l, I ~~~~~~i~~BYWP
c4 '3 fsllsd a cmina~. ~,$OTY imrn ,-~ani,$onville
mn for Forable
kslnquh rhp-wed
~ ~ t j with ~ m ayweapon/ injuf~
~ -pmde was
~ j l o w et-lat
&p~,nlPnrOfCancdinns
on 1- 1
eunviilci,
kch the vic.b-
_
nnest 03-28-Q8b SO Casi12 years of age. The ~G.mil~.ai

0 6 15-09 I M t he
his to^
t~ 8 Yean in th' Mi?'?u15
0615-09, b c ~ i r r a t c d0" 07-l,5495"d fil,@as'' On suJ?"Y'n
Ladr alsn shmved a fe:ony c ~ ~ v i i u o f 'lNf ~ o ~r ~ P - ' M ' ~ ' 2MDAMT*$500Q
"6.1 ~.~wikl~ ae~emGe 3 years oaufinem~nm.MQZroleasd f r ~ m
DePamnm*,of ~ , ~ ~ ~g~.,pemi,&~~. ~ d o on, m 11I .2-09 ' T ~ cfimind
P ~ S ~ Odro
V showed
~ . luB,r~a ir&,tered
d ~ sen aifsndcr out o f ShettfPr ofi~eI~~~~ Svitn

ijprraBeinme, paramedic Supervi,iorTOT Alreriian M E ~ ~Respon,sfi c ~ I ( A m ) &ulance new


.iuaslntliinte4ewad by Deic&ve S~CVEBiemeari iit h e Independence Police Df?!?&mment-
Bcil~g~ke s r LC
wld D)eteui,i~,cH r ~ ~ h ~that r had t d d hcr lhal "17maftaid be's goma kill me. hnt
"1 dm'' iuanr to be ;ll trouble,'' md thst ''he ltad a knife md sdd he wndd kill me."Beingue
stated that ahc asked L,C i.E .ihc knew who had bun her md LC responded, "Ycs, Randy."
rd.vired she then asked LC. who Randy wni und LC rcspondod ":
Bc<ir,,g~re mom's new
:IS

~ u i ' ' stated thsf sbe asked LC if'sl~e'knew what had happ~.ned her andLC
b ~ ~ f ~ i Dcinpe
, put his privates in
slated." ~ c she mouU2;Y*, "Ile puf-jli,i.sprivates in my b o t m ~ tlJe
his privates my fr;ont privat~s,"'&f.rue also hatI,C stated,L ~ put H medic,e
~ on me
to makc it higgfir9'and.thst Lklt went ~~XIIIG~ it ~~PPQ''' "n"

an02-03-1 1, at 2 145 hours, 83,etec~vesSchmidli and Lipps cax~dv.ctedan interview with Randy
bide aRe~:he was advised o f his Miranda Rights m.d waived his rights a d agreed to speak
wi=hthe detectives. During the interview, Lande admitted that he had done m~netbhg wrong.
Lmde acd-vist;bthat afkm he had . s & Q ~
Laade ifared 'that "LC7'had c m e noit~ -a to work9 in hadbed
filajdw),he next loin
~aid'down hm ~~~~k Ms
gtatgd he
dL advantage o f htX (LC)~ ~"'fondledm
c l bm L& dmified what he mmt by
fondling" admitted to imertiing two fingers into LC's vagilla and anus, Lande.
he s LC's vagina but "'cou~dn~t
to f i ~ r c ehi,$p t ~ i into get it that
fiad placed his on^^^^ Lande al,so
e i t h a~ h i f e Q.T verbal$i.
and in LC's vagina. ~arldfidenied e m bming dthat
t h he LC
L a d e sdmittcd that he i s a registered sex offmder in the State of h&ssowf, a d 10 bdving a
State Probation and Pasole Officer. He stated that hc was convicted ir~.Cass County oftIje sex
offense and seruard 120 d.ays.