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Case 3:11-cr-00013-JAJ -TJS Document 1

AO 91 (Rev. 5/85) Criminal Complaint Filed 01/28/11 Page 1 of 3

SOUTHERN DISTRICT OF

UNITED STATES OF AMERICA

v.

Tommy Eugene Krueger, CASE NUMBER: 3:11-mj-6

I, the undersigned complainant being duly sworn state the following is true and correct to the best of my

knowledge and belief. On or about December 13, 2010 ,in Johnson County, in the Southern District of Iowa

defendant did,

knowingly and intentionally deposit for conveyance in the mail a letter threatening
to take the life of the President of the United States,

in violation of Title 18 United States Code, Section(s) 871


_-=-:.-'-_....:.. I further state that I am a(n) Special Agent for

the United States Secret Service and that this Complaint is based on the following facts:

See Affidavit attached and incorporated

Continued on the attached sheet and made a part hereof: 1:81 Yes D No

Sworn to before me and subscribed in my presence,

January 28. 2011 at Davenport. Iowa


Date City and State

Thomas J. Shields
Chief United States Magistrate Judge
Name & Title of Judicial Officer Signature of Judicial
Case 3:11-cr-00013-JAJ -TJS Document 1 Filed 01/28/11 Page 2 of 3

AFFIDAVIT

UNITED STATES OF AMERICA)

)ss
SOUTHERN DISTRICT OF IOWA)

I, United States Secret Service Special Agent Brandon Neely, state and depose as follows:

1. I have been employed as a Special Agent by the United States Secret Service for over
two years. Prior to my employment with the United States Secret Service, I was a Special Agent
with the Iowa Department of Public Safety, Division of Criminal Investigation. During my time
employed as a Special Agent with the United States Secret Service, I have worked numerous
investigations involving threats against the President of the United States. I am aware of the
information set forth below through discussions with United States Secret Service Special Agent
Terry Johnson and the review of United States Secret Service investigative reports.

2. This affidavit is in support of a complaint charging Tommy Eugene KRUEGER with


the crime of Threats Against the President of the United States, in violation of Title 18, United
States Code, Section 87I(a).

3. On 12/17/10, the United States Secret Service, Montgomery Resident Office, was
contacted by the United States Marshal Service, Montgomery, AL in regard to an envelope
containing a letter threatening the President of the United States.

4. The envelope, which is addressed to United States Marshal Arthur D. Baylor, had a
return address of Tommy Krueger, 6947696, Iowa Medical and Classification Center, 2700 Coral
Ridge Ave., Coralville, IA 52241.

5. The letter states, "Dear: Whom it my concern. My name is tommy Krueger and I
just what to say to the FBI when I get out of prison in IA that I am going to the White House and
kill the Persident because he is a fucking muslim Fuck the USA I am a Assind for someone And
after I kill the President the I am comeing back to Iowa to kill the Govern of Iowa then I am
going to kill anybody that get in my way (sic)."

6. On 12/17/10, Special Agent Terry Johnson, Des Moines Resident Agency, responded
to the Iowa Medical and Classification Center and interviewed KRUEGER. Prior to the
interview, KRUEGER was advised of his Miranda rights.

7. KRUEGER was shown a copy of the envelope and threatening letter and advised
Special Agent Johnson that he was the author of the letter. KRUEGER advised Special Agent
Johnson that he wants to kill President Obama because President Obama is a "muslim" and
stated that he would attempt to kill the President "JFK style" referring to attacking the
President's motorcade. KRUEGER further advised Special Agent Johnson that if he did not
have an opportunity to attack the President in this manner he would wait until the President
entered the Oval Office and shoot him through the window from a building across the street.
Case 3:11-cr-00013-JAJ -TJS Document 1 Filed 01/28/11 Page 3 of 3

8. Prior to the end of the interview, KRUEGER acknowledged to Special Agent Johnson
that he knows that it is against the law to threaten the President of the United States.

9. On 12/28/1 0, Special Agent Johnson interviewed Iowa Medical and Classification


Center Correctional Officer Daniel Crawford. Officer Crawford stated that he received the
envelope containing the threatening letter directly from KRUEGER and placed his initials on the
back of the envelope after checking the envelope for contraband. Officer Crawford did not read
the contents of the envelope due to the fact that it was "legal" mail. Officer Crawford advised
that KRUEGER requested that the envelope be placed in the outgoing mail. Officer Crawford
then placed the envelope in the outgoing mail.

10. Your affiant submits that the information recited in this affidavit is to the best of my
knowledge true and accurate and petitions the court to issue a complaint charging Tommy
Eugene KRUEGER with Threats Against the President of the United States in violation of Title
18, United States Code, Section 871(a).

I declare under penalty of perjury that the above-foregoing facts and circumstances are
true and correct to the best of my knowledge and belief.

~;:~
Special Agent Brandon NeeIY:US

Signed before me this 28 th day of January, 2011.

Thomas J. Spie S(
Chief United Sta \tlx~gistrate Judge
Southern District \~wa