Criminal Complaint — No. 2:24-mj-30521 (Dkt. 1, E.D. Mich.)

Summary

Criminal complaint filed December 9, 2024 in the U.S. District Court for the Eastern District of Michigan, charging Darryl Marico King with distribution or possession with intent to distribute controlled substances under 21 U.S.C. § 841(a)(1). The affidavit of ATF Special Agent Joshua White describes three controlled purchases by an undercover agent: about three ounces of suspected cocaine for $3,000 in Howell on September 26, 2024; about 4.5 ounces of suspected cocaine and one pound of suspected methamphetamine for $6,400 in Detroit on October 9, 2024; and about 6.45 ounces of suspected cocaine for $6,000 in Howell on October 21, 2024. It says the substances field-tested positive and lists four prior felony convictions from 1992 to 2007. Magistrate Judge Kimberly G. Altman signed the complaint.

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Case 2:24-mj-30521-DUTY ECF NeusaPagelhdie Filed 12/09/24. Page                           ef) 526-9100
                                                                  Can

AO 91 (Rev. II/11) Criminal Complaint        Special Agent:      Joshua White               Telephone: (313) 202-3400

                               UNITED STATES DISTRICT COURT

                                                         for the

                                            Eastern District of Michigan

United States of America

    V.

Darryl Marico KING                                                 Case No, Case: 2:24—mj—-30521

                                                                             Assigned To : Unassigned

                                                                             Assign. Date : 12/9/2024
                                                                             Description: CMP USA V. KING (DJ)

                                              CRIMINAL COMPLAINT

        I, the complainant in this case, state that the following is true to the best of my knowledge and belief.

        On or about the date(s) of     9-26-2024, 10-9-2024, 10-21-24     in the county of _ Wayne and Livingston _ in the

      Eastern       District of       Michigan       , the defendant(s) violated:

               Code Section                                        Offense Description

21 U.S.C. § 841(a)(1)                             Distribution or Possession with Intent to Distribute Controlled Substances

        This criminal complaint is based on these facts:

see attached affidavit.

     Continued on the attached sheet.                                          Qh JWhote

                                                                                  Complainant’s signature

                                                                         Joshua White, Special Agent (ATF)
                                                                                  Printed name and title
Sworn to before me and signed in my presence
and/or by reliable electronic means.                                                °

           December 9, 2024
Date:                                                                               Judge 's signature

City and state: Detroit, Michigan                               Hon. Kimberly G. Altman, United States Magistrate Judge
                                                                                  Printed name and title

   Case 2:24-mj-30521-DUTY ECF No. 1, PageID.2 Filed 12/09/24 Page 2 of 5




                    AFFIDAVIT IN SUPPORT OF AN
              APPLICATION FOR A CRIMINAL COMPLAINT

      I, Joshua White, being duly sworn, depose and state as follows:

                                INTRODUCTION

      1.     I am a Special Agent with the Bureau of Alcohol, Tobacco, Firearms

and Explosives (ATF), and I have served as such since July 2022. Before serving

as an ATF Special Agent, I was employed by the United States Secret Service as a

Uniformed Division Officer for three and a half years. My daily responsibilities

while serving were to screen passholders and appointments who had access to the

White House Grounds, assist with protectee movements onto and off of the White

House Complex, and enforce D.C. Code, as well as Federal Law. I have completed

the Federal Law Enforcement Training Center Uniformed Police Training

program, and the Criminal Investigator Training Program with a total of over 800

hours of classroom and practical training. I have completed ATF’s Special Agent

Basic Training academy with over 500 hours of classroom and practical training. I

am presently assigned to ATF’s Lansing Office conducting narcotics/firearms

investigations.

      2.     This affidavit is based on my personal knowledge and observations,

law enforcement reports, review of relevant evidence, communications with other

sworn law enforcement personnel, communications with others who have personal

knowledge of the events and circumstances herein, and information gained through

   Case 2:24-mj-30521-DUTY ECF No. 1, PageID.3 Filed 12/09/24 Page 3 of 5




my training and experience.

      3.     This affidavit is in support of a criminal complaint and arrest warrant

for Darryl Marico KING for violations of 21 U.S.C. § 841(a)(1), Distribution or

Possession with Intent to Distribute a Controlled Substance. This affidavit is

submitted for the limited purpose of establishing probable cause. I have not

included every fact known to law enforcement related to this investigation.

                               PROBABLE CAUSE

      4.     Law enforcement has been investigating KING for drug and firearms

trafficking. Upon review of KING’s criminal history, I located the following felony

convictions for KING:

             a.    07/28/1992: 3rd Circuit Court of Michigan – Bank Robbery.

             b.    06/06/1995: 3rd Circuit Court of Michigan – Armed Robbery.

             c.    06/06/1995: 3rd Circuit Court of Michigan – Felony Weapons –

                   Felony Firearm.

             d.    12/17/2007: 7th Circuit Court of Michigan – Controlled

                   Substance – Possession less than 25 grams.

      5.     In late September 2024, investigators began preparing for a controlled

purchase of narcotics from KING. Before the controlled purchase, an Undercover

Law Enforcement Agent (UCA) engaged in recorded telephonic and text message

communication with KING over cell phone to facilitate the transaction. The UCA


                                          2

   Case 2:24-mj-30521-DUTY ECF No. 1, PageID.4 Filed 12/09/24 Page 4 of 5




and KING agreed to meet in Howell, MI, for the UCA to purchase approximately

three ounces of suspected cocaine for $3,000.

      6.    On September 26, 2024, the UCA conducted the controlled purchase

of drugs from KING. During the controlled purchase, the UCA identified KING as

the individual he was meeting with. The UCA saw KING pull a clear plastic

baggie filled with suspected cocaine from his pants, then the UCA purchased the

suspected cocaine using prerecorded government funds. The plastic baggie

containing the cocaine that KING sold to the UCA field-tested positive for the

presence of cocaine.

      7.    On October 9, 2024, the UCA conducted a second controlled purchase

of drugs from KING in Detroit, MI. At the deal location, the UCA gave KING

$6,400 in prerecorded government funds in exchange for approximately 4.5 ounces

of suspected cocaine and one pound of suspected methamphetamine. For this deal,

KING brought the drugs in a duffel bag. The UCA and KING also discussed the

sale of firearms and KING stated that he has multiple semi-automatic rifles that he

would sell the UCA for a total of $1,300. The substances the UCA purchased from

KING field-tested positive for the presence of cocaine and methamphetamine.

      8.    On October 21, 2024, the UCA conducted a third controlled purchase

of drugs from KING in Howell, MI. At the deal location, the UCA met KING

where the UCA then gave KING $6,000 in prerecorded government funds in


                                         3

   Case 2:24-mj-30521-DUTY ECF No. 1, PageID.5 Filed 12/09/24 Page 5 of 5




exchange for two plastic baggies weighing approximately 6.45 ounces of suspected

cocaine that KING pulled from his hooded pocket. During the controlled purchase,

the UCA and KING discussed the sale of 1 kg of cocaine as well as the sale of

firearms. The substances that the UCA purchased from KING field-tested positive

for the presence of cocaine.

                                  CONCLUSION

      9.     Based on the facts described above, I believe there is probable cause

that DARRYL MARICO KING violated of 21 U.S.C. § 841(a)(1), Distribution or

Possession with Intent to Distribute a Controlled Substance in the Eastern District

of Michigan.

                                             Respectfully submitted,




                                             Joshua White, Special Agent
                                             Bureau of Alcohol, Tobacco,
                                             Firearms and Explosives

Sworn to before me and signed in my
presence and/or by reliable electronic means.

 ____________________________
_____________________________________
Hon. Kimberly G. Altman
United States Magistrate Judge

   %BUFE%FDFNCFS 



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