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Case 5:23-cr-00357-GTS Document 1 Filed 03/16/23 Page 1 of 7
AO 91 (Rev. 11/11) Criminal Complaint
UNITED STATES DISTRICT COURT
for the
Northern District of New York
UNITED STATES OF AMERICA )
)
v. ) U.S. DISTRICT COURT – N.D. OF N.Y.
) Case No. 5:23-MJ-155 (ATB) FILED
CHRISTOPHER LLOYD TAYLOR, )
Mar 16 - 2023
)
) John M. Domurad, Clerk
)
Defendant. )
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 March 16, 2023, in the county of Onondaga in the Northern District of New York the defendant violated:
Code Section Offense Description
26 U.S.C. §§ 5841, 5845(a)(3), 5861(d), Possession of a Firearm (Rifle with Barrel Less than 16
5871 inches in Length) Not Registered in National Firearms
Registration and Transfer Record
This criminal complaint is based on these facts:
See attached affidavit.
☒ Continued on the attached sheet.
Complainant’s signature
Michael Renn, FBI Special Agent
Printed name and title
Attested to by the affiant in accordance with Rule 4.1 of the Federal Rules of Criminal Procedure.
Date: 3/16/2023
Judge’s signature
City and State: Syracuse, NewYork Hon. Andrew T. Baxter, U.S. Magistrate Judge
Printed name and title
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AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT
I, Michael Renn, being duly sworn, do hereby depose and state as follows:
INTRODUCTION AND AGENT BACKGROUND
1. I am a Special Agent with the FBI and have been so since 2017. I am currently
assigned to the Joint Terrorism Task Force (“JTTF”) where my primary responsibility is
conducting national security investigations involving matters of international and domestic
terrorism. Prior to employment with the FBI, I was employed as a United States Border Patrol
Agent from 2011 to 2017. Throughout my employment as a federal law enforcement officer, I
have received extensive training and I have gained experience in interviewing and interrogation
techniques, arrest procedures, search warrant applications, the execution of searches and seizures,
examination of digital and physical evidence, and various other criminal laws and procedures. I
have been afforded the opportunity to work on a significant number of criminal investigations,
including cases involving firearms and explosives.
2. I am an “investigative or law enforcement officer of the United States” within the
meaning of Section 2510 (7) of Title 18, United States Code, that is, an officer of the United States
who is empowered by law to conduct investigations and to make arrests for offenses enumerated
in Section 2516, Title 18, United States Code.
3. This affidavit is founded on my personal knowledge based on my participation in
this investigation, including the review of reports by myself and/or other law enforcement agents,
communication with others who have personal knowledge of the events and circumstances
described herein, and information gained through my training and experience. The information
outlined below is provided for the limited purpose of establishing probable cause and does not
contain all details or all facts known to me regarding this investigation.
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4. I submit this affidavit in support of a criminal complaint charging CHRISTOPHER
LLOYD TAYLOR with a violation of Title 26 U.S.C. §§ 5841, 5861(d), 5871 [Possession of an
Unregistered Firearm].
Applicable Law as to Alleged Offense
5. Title 26, United States Code, Section 5861 provides, in pertinent part, that, “It shall
be unlawful for any person--…(d) to receive or possess a firearm which is not registered to him in
the National Firearms Registration and Transfer Record…”
6. Title 26, United States Code, Section 5845(a) defines the term “firearm” to
purposes of Chapter 53 of Title 26, to include “a rifle having a barrel or barrels of less than 16
inches in length” and “a weapon made from a rifle if such weapon as modified has an overall
length of less than 26 inches or a barrel or barrels of less than 16 inches in length.” This includes
weapons that are readily restored to firing condition.
7. According to Title 26, United States Code, Section 5845(b), a “rifle” means a
weapon designed or redesigned, made or remade, and intended to be fired from the shoulder and
designed or redesigned and made or remade to use the energy of the explosive in a fixed cartridge
to fire only a single projectile through a rifled bore for each single pull of the trigger, and shall
include any such weapon which may be readily restored to fire a fixed cartridge.”
8. In order to legally possess a rifle with a barrel less than 16 inches in length (a
“Short-Barreled Rifle” or “SBR”) in the United Sates, the Short-Barreled Rifle would have to be
registered through ATF in the National Firearms Registration and Transfer Record (NFRTR) and
the purchase made through an individual with a valid FFL (Federal Firearms License).
9. A violation of Title 26 U.S.C. § 5861(d) for possession of an unregistered firearm,
such as a Short-Barreled Rifle, involves the following elements: (1) the defendant possessed a
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“firearm” as defined in the National Firearms Act, 26 U.S.C. § 5845; (2) the defendant knew he
possessed the firearm; (3) the firearm was or could have readily been put into operating condition;
and (4) that the firearm was not registered to the defendant in the National Firearms Registration
and Transfer Record.
BASIS FOR PROBABLE CAUSE
10. On March 10, 2023, the Honorable Andrew T. Baxter, a U.S. Magistrate Judge in
the U.S. District Court for the Northern District of New York, issued a search warrant (the
“Warrant”) for the property located at 304 Wilson Street, Syracuse, New York 13203 (the
“Premises”), the person of Christopher Taylor, and a 2017 Chevrolet Equinox. The Warrant
authorized the seizure of, among other items, any firearms and ammunition.
11. In executing the Warrant on March 16, 2023, law enforcement searched the
Premises and found a short-barreled AR-15-style rifle (the “Firearm”) in a gray duffel bag on the
floor in the closet of the master bedroom of the Premises. Inside the duffel bag, law enforcement
found an upper and lower receiver: the upper receiver of the Firearm was a black metal barrel with
a black tactical-style flashlight with no manufacturer’s marking or serial numbers; the upper
receiver had a barrel that was measured to be 12.875 inches from the end of the flash suppressor
to closed breech face, and therefore had a barrel less than 16 inches in length. The lower receiver
of the Firearm was stamped with the manufacturer’s name “Spikes Tactical” and labeled with
Model Number ST15 with Serial Number SHM008427. Also contained in the duffel bag were
several metal rifle magazines.
12. Photos of the firearms are displayed below, which show the measurement of the
barrel length and the upper and lower receivers:
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13. Based on my training and experience and after consultation with experts from the
Bureau of Alcohol, Tobacco, Firearms, and Explosives (“ATF”), the upper and lower receivers of
the Firearm could be readily restored to firing condition by securing the upper and lower
assemblies with two takedown pins and could be assembled to firing condition within a minute.
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14. On March 8, 2023, a query through ATF records confirmed that TAYLOR does not
have any firearms, including a Short-Barreled Rifle such as the Firearm, registered in the National
Firearms Registration and Transfer Record (NFRTR).
15. On March 16, 2023, TAYLOR was interviewed by the FBI and ATF at the FBI
office in Syracuse, New York. That interview was audio and video recorded. While at the FBI
office and after waiving his Miranda rights, TAYLOR acknowledged that he owned an
approximately 11.5-inch barrel upper receiver, which he told investigators was in a bag in a closet
in the master bedroom at the Premises. Furthermore, TAYLOR stated that he readily and often
interchanged the upper and lower assemblies of the rifles that he owned and admitted that he had
shot the Firearm in that configuration. TAYLOR also stated that he had purchased the upper
receiver containing the 11.5-inch barrel from Palmetto State Armory, an online firearm and firearm
parts retailer based in South Carolina.
16. Records from Palmetto State Armory show that on or about March 19, 2020,
TAYLOR purchased the following items, which included an AR-15 upper receiver with a 11.5-
inch short-barrel described as a “pistol kit”:
17. Based on my training and experience, I know that such pistol kits sold by Palmetto
State Armory are readily interchangeable and often purchased and used to assemble short-barreled
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rifles (SBRs), meaning the weapon was designed or redesigned, and intended to be fired from the
shoulder (as more fully defined in 26 U.S.C. 5845(c)).
CONCLUSION
18. Based on the foregoing, your affiant submits that there is probable cause to
conclude that on March 16, 2023, in Onondaga County, New York, Christopher Lloyd TAYLOR
violated Title 26, United States Code, Sections 5841, 5861(d), and 5871 for possessing a firearm
that was not registered to him in the National Firearm Registration and Transfer Record.
Attested to by the affiant,
_________________________
Michael Renn
Special Agent
Federal Bureau of Investigation (FBI)
I, the Honorable Andrew T. Baxter, United States Magistrate Judge, hereby acknowledges that this
affidavit was attested by the affiant by telephone on March 16, 2023, in accordance with Rule 4.1
of the Federal Rules of Criminal Procedure:
___________________________
Hon. Andrew T. Baxter
United States Magistrate Judge
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