Criminal Complaint — No. 2:21-mj-30442 (Dkt. 1, E.D. Mich.)
Summary
A criminal complaint in the U.S. District Court for the Eastern District of Michigan, Case 2:21-mj-30442, filed as ECF No. 1 of 9 pages and marked a sealed matter, charging Devin King. The complainant, Special Agent Mary Behler of the ATF, states that on or about July 29, 2021, in the county of Wayne in the Eastern District of Michigan, the defendant violated 18 U.S.C. 922(g)(1), felon in possession of a firearm, with the facts continued in an attached affidavit in support of a criminal complaint based on her participation in the investigation, including witness interviews. The complaint and affidavit were sworn on September 20, 2021 before Honorable Kimberly Altman, U.S. Magistrate Judge, at Detroit, Michigan.
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“Criminal Complaint — No. 2:21-mj-30442 (Dkt. 1, E.D. Mich.).”
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Case 2:21-mj-30442-DUTY ECF No. 1, PageID.1 Filed 09/20/21 Page 1 of 9
AO 91 (Rev. ) Criminal Complaint
UNITED STATES DISTRICT COURT
for the
Eastern District of Michigan
United States of America
v.
Case: 2:21−mj−30442
Case No. Assigned To : Unassigned
Devin KING Assign. Date : 9/20/2021
USA V. SEALED MATTER (CMP)(CMC)
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 July 29, 2021 in the county of Wayne in the
Eastern District of Michigan , the defendant(s) violated:
Code Section Offense Description
18 U.S.C. 922(g)(1) Felon in possession of a firearm
This criminal complaint is based on these facts:
Continued on the attached sheet.
Complainant’s signature
Special Agent Mary Behler - ATF
Printed name and title
Sworn to before me and signed in my presence
Date: September 20, 2021 Judge’s signature
City and state: Detroit, Michigan Honorable Kimberly Altman, U.S. Magistrate Judge
Printed name and title
Case 2:21-mj-30442-DUTY ECF No. 1, PageID.2 Filed 09/20/21 Page 2 of 9
AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT
I, Special Agent Mary E. Behler, being first duly sworn, hereby depose and
state as follows:
INTRODUCTION & AGENT BACKGROUND
1. I make this affidavit from personal knowledge based on my
participation in this investigation, including witness interviews by myself and/or
other law enforcement agents, communications 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
each and every fact and detail of which I and other law enforcement officers are
aware relating to this investigation.
2. I have been a Special Agent (SA) with the Bureau of Alcohol, Tobacco,
Firearms, and Explosives (ATF) since December of 2013. Prior to becoming a
Special Agent with ATF, I was a Federal Air Marshal with the Federal Air Marshal
Service for approximately three years. I completed the Federal Law Enforcement
Basic Training Course in Artesia, New Mexico, the Federal Air Marshal Basic
Training Academy in Atlantic City, New Jersey, the Criminal Investigator Training
Program in Glynco, Georgia, and the ATF Special Agent Basic Training at the
Federal Law Enforcement Training Center in Glynco, Georgia. I obtained a Master
Case 2:21-mj-30442-DUTY ECF No. 1, PageID.3 Filed 09/20/21 Page 3 of 9
of Science degree in Law Enforcement Intelligence Analysis and a Bachelor of Arts
degree in Criminal Justice from Michigan State University.
3. I am currently assigned to the Detroit Field Division, Group IV, which
is responsible for conducting investigations related to the illegal use and/or
possession of firearms, armed drug trafficking, and organized crime investigations.
I have participated in numerous investigations of organized crime and have
conducted or participated in a variety of types of surveillance, the execution of
search warrants, and the debriefing of informants and cooperating witnesses. I have
also participated in investigations involving Title III wiretaps, including serving as
the affiant in an application to intercept wire and electronic communications for
four (4) target telephones, two (2) extensions, and numerous consensually recorded
lines. In addition, I have reviewed recorded conversations and records relating to
various organized crime activities including, but not limited to, homicides, assaults,
robberies, drug trafficking, illegal firearms possession, and wire fraud. Through
my training, education, and experience, I have become familiar with the way that
organized crime is conducted and the methods of payment for such crimes.
4. During my employment with ATF, I have participated in numerous
criminal investigations focused on firearms, armed drug trafficking violations, and
criminal street gangs. I have investigated violations of Title 18, United States Code,
Section 1962 (Racketeering Influenced Corrupt Organizations Act) and Title 18,
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Case 2:21-mj-30442-DUTY ECF No. 1, PageID.4 Filed 09/20/21 Page 4 of 9
United States Code, Section 1959 (Violent Crimes in Aid of Racketeering) with
successful adjudications. Through these investigations, my training and experience,
and conversations with other agents and law enforcement personnel, I have become
not only familiar with firearms violations, but also with methods used by gang
members and drug traffickers to smuggle and safeguard controlled substances, to
distribute controlled substances, and to collect, launder, hide, disguise or conceal
related proceeds. I am familiar with methods employed by gang members and large
narcotic organizations to attempt to thwart investigations into their criminal
activity. These tactics, employed in part to evade law enforcement, include their
criminal use of and association with multiple residences, multiple cellular phones,
counter surveillance, smuggling schemes, false or fictitious identities, coded
communications and conversations, and the use of firearms to facilitate the illegal
activity. Additionally, I have reviewed numerous social media accounts and phone
downloads belonging to suspected gang members and/or associates, and am
familiar with how these devices are used as a means to communicate with other
members and to promote a gang’s enterprise and racketeering activities.
PURPOSE OF AFFIDAVIT
5. The purpose of this affidavit is to establish probable cause that Devin
KING a/k/a “Devy Dev” (DOB 06/XX/1999) violated 18 U.S.C. § 922(g)(1) (felon
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Case 2:21-mj-30442-DUTY ECF No. 1, PageID.5 Filed 09/20/21 Page 5 of 9
in possession of a firearm) on or about July 29, 2021, in the Eastern District of
Michigan.
6. In September of 2021, your Affiant reviewed a Computerized Criminal
History (CCH) of KING, which revealed KING has been convicted of the following
felony:
a. 2020 – KING pled guilty to Attempt – Felony Weapons –
Carrying Concealed in the 37th District Court, Macomb County,
Michigan.
7. Based on KING’s criminal history, particularly the recentness of his
2020 guilty plea, probable cause exists that KING knew that he had previously been
convicted of at least one felony offense punishable by imprisonment for more than
one year.
PROBABLE CAUSE
8. On August 18, 2021, your Affiant reviewed documents regarding the
July 29, 2021 arrest of KING, during which two firearms and ammunition were
recovered. Specifically, Detroit Police officers recovered a loaded Romarm/Cugir
Micro Draco, 7.62x39 caliber semi-automatic firearm and a loaded Romarm/Cugir
Mini Draco, 7.62x39 caliber semi-automatic firearm. Below is a summary of the
events that transpired on July 29, 2021:
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Case 2:21-mj-30442-DUTY ECF No. 1, PageID.6 Filed 09/20/21 Page 6 of 9
a. On July 29, 2021, Detroit Police Officers were dispatched to
O.H. Pye funeral home for a report of a group of individuals
who were armed with large pistols. During their investigation,
officers learned the group of males were hired by the family
after shots were fired during the deceased individual’s repast
approximately one (1) week prior. The funeral home requested
the officers to standby for safety reasons.
b. When the funeral began to release, officers observed a large
fight break out between two (2) groups of individuals. Officers
observed a black male, wearing no shirt and black pants (later
identified as Devin KING) fighting with another male at the
location. While breaking up the fight, officers observed KING
enter the driver’s side seat of a black Ford Fusion, bearing a MI
license plate, and produce a micro-Draco, AK-style pistol from
the driver’s side floorboard. Officers ordered KING to drop the
weapon. Officers observed KING place the firearm back into
the driver’s side of the vehicle. Officers then observed KING
flee on foot westbound toward Plymouth.
c. Officers radioed Detroit police units with KING’s description.
Detroit officers observed KING walking westbound on
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Plymouth Road. Officers requested KING to stop to which
KING responded “No” and proceeded to enter the rear
passenger side of a white 2018 Chrysler 300 and attempted to
leave the scene. Officers initiated a traffic stop of the Chrysler
300 in the area of Plymouth/Glastonbury Street. KING and the
driver of the vehicle, identified as Known Person #1, were
detained. Officers arrested Known Person #1 for driving with
license suspended (DWLS) and KING was detained in the back
of a scout car.
d. Detroit Police Officers recovered a Ford key fob from KING.
Officers conducted a LEIN query of the previously mentioned
Ford Fusion which revealed the vehicle is uninsured and
eligible for a tow.
e. Officers utilized the key fob to unlock the doors on the Ford
Fusion and conducted an inventory search of the vehicle.
Officers recovered the following:
i. One (1) Romarm/Cugir Micro Draco, 7.62x39 caliber semi-
automatic firearm containing a loaded magazine and one live
round in the chamber from the driver’s side floor board.
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ii. One (1) Romarm/Cugir Mini Draco, 7.62x39 caliber semi-
automatic firearm containing a loaded magazine and one live
round in the chamber from the rear passenger’s seat, located in
a multi-color book bag.
iii. Devin KING’s identification card located from the center
console of the vehicle.
f. Detroit Police officers arrested KING for Carrying a Concealed
Weapon (CCW) and transported him to the Detroit Detention
Center for processing.
g. The abovementioned firearms and ammunition were taken into
custody and placed on evidence. The firearms were test fired
and submitted for NIBIN analysis.
9. On September 10, 2021, I contacted Interstate Nexus Expert ATF
Special Agent Michael Jacobs. SA Jacobs advised, based upon the description
provided, without physically examining the firearms, that the firearms are firearms
as defined under Title 18 United States Code, Section 921 and were manufactured
outside of the state of Michigan after 1898, and therefore the firearms had traveled
in and affected interstate commerce.
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CONCLUSION
10. Based upon the above information, probable cause exists to believe that
Devin KING, a prior convicted felon, did knowingly and intentionally possess
firearms, to wit: a Romarm/Cugir Micro Draco, 7.62x39 caliber semi-automatic
firearm and a Romarm/Cugir Mini Draco, 7.62x39 caliber semi-automatic firearm
and those firearms having traveled in interstate commerce, in violation of 18 U.S.C.
§ 922(g)(1) (felon in possession of a firearm). This violation occurred on or about
July 29, 2021, in the Eastern District of Michigan.
__________________________
Special Agent Mary E. Behler
Bureau of Alcohol, Tobacco, Firearms and Explosives
Subscribed and sworn before me or
by reliable electronic means.
Honorable Kimberly Altman
United States Magistrate Judge
Dated: September 20, 2021
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