led 22 January 27 A10:44 Marilyn Burgess - District Clerk Harris County EA001_1108352 IN THE 232ND DISTRAXTCRFERT CAUSE NO. 175640801010 THE STATE OF TEXAS 8 § vs. § OF § § SMITH, RYAN HARRIS COUNTY, TEXAS MOTION FOR SUFFICIENT BAIL THE STATE OF TEXAS, by and through its Assistant District Attorney, requests this Court enter a sufficient bail pursuant to Tex. Code Crim. Proc. Ann. Arts. 17.09(3), 17.15. Sufficient and non-oppressive bail is required to give proper consideration to the nature of the offense, protect the safety of the victim and community, and provide reasonable assurance that the defendant will return 1 On January 23, 2022, Defendant Ryan Smith was released on a combined $50,000 bond for the offenses of robbery (1755835) and interference with a police service animal (1756410). Also on January 23, 2022, Defendant Ryan Smith was ordered by Harris County Magistrate Cheryl Diggs, acting on behalf of this court, to abide by bond conditions, including but not limited to 1. Defendant shall personally appear in court, on time, every time this case is set on the court's, docket, unless the judge waives the appearance. 2. Defendant shall commit no crime and shall not engage in any conduct that could result in his arrest. 3. Defendant must not use or possess a firearm. 4. Other: No weapons, firearms or ammunition I. On January 24, 2022, the Defendant was scheduled to appear in the 232nd District Court for his preliminary court setting. The Defendant did not appear personally. ML On or about January 25, 2022, law enforcement was at the Harris County home of Mr. Cameron Smith, father of Defendant Ryan Smith, investigating a missing persons report. While investigating at that location, Defendant Ryan Smith was observed by law enforcement down the street from the home driving a black GMC Denali pickup truck, consistent with the truck registered to Mr. Cameron Smith and missing from his residence. Defendant Smith was operating the truck ‘with no headlights at night nor any front or rear license plates. Due to these infractions and other suspicious circumstances regarding the vehicle being driven by Defendant Smith, a traffic stop was attempted, Defendant Smith failed to stop the vehicle and led police on a chase for approximately 10 miles (15 minutes) before crashing the vehicle and evading on foot. Discovered in the vehicle was a loaded hunting rifle where Defendant's Smith’s leg would have been as he was driving and a black Labrador Retriever. In the bed of the vehicle was a 15-pound metal dumbbell with blood on it and a tent CAUSE NO, 175640801010. DEFENDANT: SMITH, RYAN MOTION FOR SUFFICIENT BAIL - Page 1 of 4Also on January 25, 2022, the body of Defendant Ryan Smith’s father, Cameron Smith, was discovered in the garage of his residence. It was immediately evident from the blood at the scene and a plastic bag discovered around Mr. Cameron Smith’s head that Mr. Cameron Smith’s death ‘was not a result of natural causes Later on January 25, 2022, Defendant Ryan Smith was taken into custody in Austin County on outstanding warrants for violation of his bonds in his pending robbery and interference with a police service animal cases. Defendant Smith provided a statement indicating that he had killed Mr. Cameron Smith on January 24", 2022, by distracting him and then striking him in the head 3 times with a 15-pound dumbbell before tying a plastic bag around Cameron Smith’s head. Defendant Smith stated he then took Cameron Smith’s truck and brought the dumbbell with him. WV. ‘As detailed by the foregoing, Defendant Ryan Smith was already on bond for two separate felonies when he committed the murder of Mr. Cameron Smith or January 24, 2022. Defendant Smith was also on bond for the misdemeanor offense of evading arrest or detention. Following the murder of Mr. Cameron Smith and while still on bond in the aforementioned 3 cases, on or about January 25, 2022, Defendant Ryan Smith committed multiple criminal infractions, including but not limited to driving with no headlights at night, evading arrest or detention in a motor vehicle, evading arrest or detention on foot, and unlawful carrying of a weapon. v, ‘As detailed by the foregoing, Defendant Ryan Smith was in violation of multiple conditions of his bond ordered by this cour, including but not limited to committing no crime and engaging in ‘no conduct that could result in his arrest, possessing a firearm, and possessing ammunition VI As detailed by the foregoing, Defendant Ryan Smith used a deadly weapon during the murder of Mr. Cameron Smith. Vo. Less than one day after being released from the Harris County Jail on bond for two violent felonies and evading, Defendant Ryan Smith killed his father in his own home by striking him three times with a dumbbell and tying a bag around his head. He then hid his father’s body before taking his father’s truck, ultimately using it to evade from law enforcement, Defendant Ryan Smith was later located in Austin County and had to be brought back to Harris County to face charges. Defendant Ryan Smith poses a substantial and undeniable danger to the community, including his own family. He also poses a serious risk of flight as demonstrated by his multiple flights from law enforcement related to the offenses with which he is currently charged and his failure to appear at his court date. VIL The State respectfully requests that the Court consider the violent nature of the offense and the aggravating factors described above, Defendant Ryan Smith’s previous failure to appear for court, Defendant Ryan Smith’s failure to abide by the conditions of his bond, Defendant Ryan CAUSE NO, 175640801010. DEFENDANT: SMITH, RYAN MOTION FOR SUFFICIENT BAIL - Page 2 0f 4Smith’s commission of new serious offenses while on multiple felony bonds, and Defendant Ryan’s Smith’s use of a deadly weapon during the commission of this offense and set a sufficient and non- oppressive bail in the amount of $2,000,000. RESPECTFULLY SUBMITTED, (s(Lindsey Bondurant ____ Lindsey Bondurant Assistant District Attorney Harris County District Attomey’s Office TBC No. 24086498 ‘CAUSE NO, 175640801010. DEFENDANT: SMITH, RYAN MOTION FOR SUFFICIENT BAIL - Page 3 of 4CERTIFICATE OF SERVICE I, the undersigned attomey, hereby certify that a true and correct copy of this instrument was e-mailed to counsel for the Defendant on this date by electronic service using his State Bar of Texas official address for electronic service Is/Lindsey Bondurant Lindsey Bondurant Assistant District Attorney Harris County District Attorney’s Office TBC No. 24086498 CAUSE NO, 175640801010. DEFENDANT: SMITH, RYAN MOTION FOR SUFFICIENT BAIL - Page 4 of 4CAUSE NO. 175640801010 THE STATE OF TEXAS § IN THE 232ND DISTRICT COURT § vs. § OF § § SMITH, RYAN HARRIS COUNTY, TEXAS ORDER Having considered the State’s Motion for Sufficient Bail, the State’s request for Error! Reference source not found. bail is GRANTED SIGNED AND ENTERED on Judge Presiding Harris County, Texas CAUSE NO. 175640801010 DEFENDANT: SMITH, RYAN ORDER ON MOTION FOR SUFFICIENT BAIL - Page 1 of 1