FI I-E D

AO 9l (ltev. 1ll11) CrirniDd Complaint MAp 1 n

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UmrBo Srarps DtsrRrcr CouRur*, u.s. Disrfict & Bankruptcv
for the Courti torttre oistrict ol Columbla

District of Columbia

United States of America )

) Case: 1:17-ml-000185
MIA K. HILL ) Assigned To : Magistrate Judge Robin M. l\4eriweather
alkla laleah Michelle Everett ) Assign. Date : O3l3OnO17
DOB: 10/03/1996 ) Description: Criminal Complaint
PDID:713-627 )
)
Defendant(s)

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best ofmy knowledge and belief.
On or about the date(s) of March 29.2017 in the county of Washington in the

District of Columbia , the defendant(s) violated:

Code Section Offense Description

18 USC 1 I 1(b); did forcibly assault, resisl, oppose, impede, intimidate and interfere with
18 USC 1361 Officers Pierre, Greene, Ruiz, and Riley, officers or employees of the United
50 DC Code 220'1.05b(bx2) (2001 States or an agency in a branch of the United States govemmenl, while said
ed.) offlcers, were engaged in the performance of official duties, and the
defendant, in so doing, did use a deadly or dangerous weapon, to attempt to
inflict bodily injury; willfully and by means of stricking into several vehicles,
did attempt to injure and commil a depredation against property of the United
States, property which had been constructed for the United States (cont'd)

This criminal complaint is based on these facts:

See Attached Statement of Facts

d Continued on the attached sheet

V-\Q-. ! \e\a^
Complatnant s signoture

KATHRYN RIVERA, Special Agent

Printed hafie and title

Sworn to before tne and signed in my presence.

Date: 03t30t2017
's signalure

City aDd state: Washington, DC ROBIN M..MERIWEATHER, U.S. Magistrate Judge

['ri]1ted ninle and litle
AO9l (ltev. I l/ll) Crimirral (omplainl

Uxrrpo Srares DrsrRrcr Counr

fbr the
District of Columbia

Unitcd States of Amcrica )

)
) Case No.
MIA K, HILL
a/lda Taleah Michelle Everett )
DOB: '10/03/1 996 )
PDID: 713-627 )
)

CRIMINAL COMPLAINT
l. the complainant in this case, slate that the tbllorving is true to the best of my knorvledge and beliell
On or about the date(s) of March 29, 2 017 in lhe counl\ ol' Washington in thc
l)islrict ol' Columbia . thc def'endanl(s) violatcd

Code Sec'litn Olfbnse Description

18USC111(b); in excess of $1000; and while operating a motor vehicle, did knowingly fail
18 USC 1361 and refuse to bring that motor vehicle to an immediate stop, and did attempt
50 DC Code 2201.osb(b)(2) (2001 to elude a law enforcement officer, following a law enforcement officer's
ed.) signal to bring the motor vehicle to a stop and operated the motor vehicle in a
manner that would constitute reckless driving.

This criminal complaint is bascd on these facts

See Attached Statement of Facts

d Continued on the attached sheet

Conlpktinant s signoIure

KATHRYN RIVERA, Special Agent

j'rinted tuDrc dnd titl?

Swonl to befbre me and signed in my presence

[)ate: 03130/2017
.llrlge .\ \igtldure

Citv and state Washington, DC ROBIN M. MERIWEATHER, U.S. l\4agistrate Judge

I'ri ted na rc dnd litle
 FILED
MAR 3 0 2017

ann'r o,rvrr nq supp onr or cn*,N * co u p rarNdrilli i;lir? iYli1,1 ii$ f#ffi
Kathryn Rivera, a Special Agent with the United States Capitol Police, Washington, D.C.,

(hereinafter "youl affianf') being duly swom, deposes and states as follows:

1. Your affiant is a Special Agent ("SA") with the United States Capitol Police

('USCP"), Criminal Investigations Section. I have been a police officer for approximately fifteen

years and have been assigned to tl-re Criminal Investigations Section since 2011. I have

investigated offenses involving assaults with a deadly weapon, assaults on a police officer, and

aggravated assaults.

2. This aflidavit is based, in part, upon my personal observations, infotmation

provided to me by other USCP officers, witnesses, review of surveillalce video, and other

information gathered during the course of this investigation. Since this affrdavit is being submitted

for the limited purpose of obtaining a criminal complaint and arrest warrant, I have not included

each and every fact known to me conceming this investigation. I have set forth only the facts

which I beiieve are necessary to establish probable cause for a criminal complaint.

3. This affidavit is submitted in support of an application for a criminal complaint

charging MIA KEYSHIA HILL, also known as Taleah Michelle Everett (hereinafter, "Hill") with:

four counts of Assaulting, Resisting, or Impeding Certain Officers or Employees with a Dangerous

Weapon, in violation of Title 18, United States Code $ 1 1 1(b), one count of Willfully lnjuring or

Committing any Depredation Against Ary Property of the United States, in violation of Title 18,

United States Code $ 1361, and one count of Fleeing a Law Enforcement Off1cer, in violation of

50 D.C. Code $ 2201.05b (b)(2)(2001 ed.)).

4. As a result of my personal participation in this investigation, as well as through

interviews with witnesses and analysis of reports submitted by other USCP officers, I am familiar

Case: 1;17-mj-OOOlBs
Assgned To Magstrate Judge Robin M Meriweather
Assn Date .0381t2o17 -
Descriptjon: Criminal Complaint
 with all aspects of this investigation. On the basis of this familiarity, and on the basis of other

information which I have reviewed and determined to be reliable, I allege the following facts to

show there is probable cause to believe that Hill assaulted one or rnore USCP officers with a

dangerous weapon, in violation of Title 18, United States Code $ I 11(b), destroyed or depredated

U.S. property in violation of Title 18, United States Code, $ i361, and fled and eluded USCP

officers in violation of 50 D.C. Code $ 2201 .05b (b)(2).

5. Under Title 18, United States Code, $ 111@), whoever forcibly assaults, resists,

opposes, impedes, intimidates, or interferes with a USCP officer while the offrcer is engaged in or

on account of the performance of officials duties, and in the commission of such acts uses a

dangerous weapon, shall be fined or imprisoned for not more than 25 yeNs.

6. Under Title 18, United States Code, $ 1361, whoever willfully injures or commits

a depradation against property of the United States, shall be fined not more than $250,000 or

imprisoned for not more than l0 years, or both.

7. Under 50 D.C. Code $ 2201.05b (b)(2), whoever knowingly fails or refuses to bring

a motor vehicle to an immediate stop, or who flees or attempts to elude a law enforcement officer,

following a law enforcement officer's signal to bring the motor vehicle to a stop in a manner that

would constitute reckless driving, or causes propefty damage or bodily injury, shall be fined not

more than the amount set forth in $ 22-3571.01, or imprisoned for not more than 5 years, or both.

Hill's Initial Encounter with Law Enforcement

8. On March 29,2017, at approximately 9:23 a.m., USCP Officer Pierre, a uniformed

officer, observed Hill operating a dark colored four-door Chevrolet Cruze, bearing Maryland

registration with a vehicle identification number later identified as

2
XXX)O(XXXXXXXXX, traveling eastbound in the 300 block of Independence Avenue SW.

USCP Officer Piere attempted to stop Hill by waving his anns after he obseryed her drive through

a solid red traffic signal at the intersection of 3'd Street SW. USCP Officer Pierre was forced to

move out of Hill's way as she igrored his attempt to stop her and drove past him. At the time that

Hill drove through the red light, she nearly hit two pedestrians who were walking in the crosswalk

and crossing lndependence Avenue SW.

9. Hill ignored USCP Officer Pierre's efforts to stop her vehicle and displayed her

middle finger upright in USCP Offrcer Pierre's direction as she continued driving east on

Independence Avenue SW.

Hil!,Ignores Second Attempt bv USCP Officers to Pqll lQve! Eer Vehicle

10. As Hill continued traveling eastbound in the unit block of Independence Avenue

SE, she abruptly changed lanes without caution twice, but was forced to stop due to heavy traffic

due to a solid red signal at the intersection of ls Street and Independence Avenue SE.

l1- While Hill's vehicle was stopped in traffic, USCP Officer J. Greene, USCP Officer

Goldsmith, and USCP Officer Langley - all of whom were in USCP uniforms and in marked

USCP cruisers - pulled alongside Hill's vehicle. USCP Officer Goldsmith approached Hill's

vehicle and ordered her to exit the vehicle. Hill ignored USCP Officer Goldsmith's commands to

exit and remained in her vehicle clenching the steering wheel.

12. Hill then began perfonning a U-tum by turning to the ieft and pulling between

USCP Officer J. Greene's and USCP Offrcer Langley's marked USCP cruisers. Hill stopped,

backed up, directed her car towards USCP Officer Goldsmith and lbrced him to jump out of the

way to avoid being struck. While disregarding the USCP officers' commands to stop, Hill struck

3
USCP Officer J. Greene's USCP police vehicle and collided with a gray Toyota Coroll4 before

she pulled forward and fled the scene of the crash, traveling westbound in the unit block of

lndependence Avenue SE.

Hill Isnores Third Attempt by USCP Officers to Pull over Her Vehicle

13. USCP Officer Ruiz, wearing a USCP mountain bike uniform, stepped into the

roadway and attempted to stop Hill by fully extending his left arm with his palm facing Hill's

vehicle. Hill refused to stop and accelerated towards USCP Officer Ruiz. Hill ignored IJSCP

Officer Ruiz's commalds and swerved her vehicle, crossing over the double yellow lane divider

in USCP Officer Ruiz's direction. Hill did not stop as she drove towards USCP Officer Ruiz.

14. Hill changed lanes without caution in the intersection of South Capitol Street and

Independence Avenue SW. While traveling westbound in the unit block of Independence Avenue

SW, Hill crossed over the double solid yellow lines and began traveling westbound in the

eastbound lanes directly towards oncoming traffic. Multiple vehicles were forced to change lanes,

slow down, or brake to avoid a collision with Hill. Two marked USCP police vehicles with their

emergency equipment activated maneuvered behird Hill and attempted to pull her over, but she

continued westbound in the eastbound lanes until the intersection of 100 block of Independence

Avenue SW.

Hill's Vehicle Ultimately Forced to Stop 411", gurr'cades Were Raised to Block Her Travel

15. While in the 100 block of Independence Avenue SW, USCP ofhcers activated and

raised barricades embedded in Independence Avenue SW to force all eastbound and westbound

traffic to stop, includi-ng Hill. While Hill was stopped, Hill's vehicle was surrounded by USCP

Officer Riley and other USCP officers who were all on foot and dressed in USbP unifomrs. Law

4
 enforcement repeatedly ordered Hill to exit her vehicle, however Hill ignored the commands from

law enforcement.

16. USCP Officer .I. Greene positioned his vehicle behind and to the left of Hill's

vehicle. After Hill ignored repeated commands to exit her vehicle, USCP Officer Riley broke the

rear window of Hill's vehicle while another USCP officer was attempting to open Hill's doors.

Another USCP officer moved to the driver's door window in an attempt to break it when Hill

suddenly pulled the vehicle forward, forcing Officer Riley and other USCP uniformed officers and

a USCP plain-clothed officer to move out of the way in fear of being struck by Hill.

17. Hill then put her vehicle into reverse and collided into USCP Officer .I. Greene's

marked USCP patrol vehicle, causing significant and disabling damage in excess of$1,000. As

Hill was reversing, she was in close proximity to the USCP officers who were attempting to stop

the vehicle as well.

18. Wrile Hill was in reverse and colliding into USCP Officer J. Greene's vehicle, two

uniformed USCP offrcers in fear of their own immediate safety, as well as the immediate safety of

all USCP officers on scene and the immediate safety of passersby, discharged their firearms at

Hill's vehicle.

19. USCP Officer fuley was able to break the driver's door window of Hill's vehicle,

allowing USCP Officer D. Greene to reach into the vehicle and remove Hill from the driver's seat

and place her into custody.

20. Hill was not inj ured as a result of USCP officers discharging their firearms and

refused any medical treatment on scene. No witnesses, vehicle operators or passersby reported

any injuries. No USCP officers were injured as a result of Hill's actions, however Hill spat

5
multiple times at multiple uniformed USCP officers while yelling something to the effect of: fuck

you, I was up here yesterday fying to run you motherfuckers over!

21. An NCICiWALES check of Hill reveaied that she did not possess a valid permit to

operate a motor vehicle in the District of Columbia. Hill was transported to 119 D Street NE for

processing and was advised of her Miranda rights, which she waived. Hill's vehicle was

impounded at 67 K Street SW pending further investigation.

CONCLUSION

22. Based on the aforementioned factual information, I respectfully submit that there is

probable cause to believe that MIA KEYSHIA HILL committed violations of 18 U.S.C. $ 1i 1(b)

(Assaulting, Resisting, or Impeding Certain Officers or Employees with a Dangerous Weapon),

one count of Willfully Injuring or Committing any Depredation Against Any Property of the

United States, in violation of Title 18, United States Code $ 1361, and one count of Fleeing a Law

Enforcement Ofiicer, in violation of 50 D.C. Code $ 2201.05b (b)(2)(2001 ed.)).

\\?-ri.xqa.-
SPECIAL AGENT KATHR\N RIVERA
LINITED STATES CAPITOL POLICE

Subscribed and swom to before me this 30fi day of March,2017.

.4
HON. ROBIN M. WEATHER
L]NITED STATES MAGISTRATE JUDGE