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Criminal Complaint — United States v. Alante Malik Jackson, No. 1:21-mj-06156-JES-JEH (Dkt. 1, C.D. Ill.)

Summary

ATF Special Agent Kevin Brown's criminal complaint in the Central District of Illinois charges Alante Malik Jackson with possessing a firearm after a prior Illinois conviction for a crime punishable by more than one year, in violation of Title 18, Section 922(g), on or about September 20, 2021 in Peoria County. The affidavit says Peoria police saw Jackson leave a Shell gas station carrying a backpack, get into a black Dodge Charger believed to be stolen, and flee at a high rate of speed. After officers caught Jackson on foot, a witness reported seeing Jackson throw something onto the roof of a garage, where officers found a Glock, Model 23, .40 caliber pistol. The affidavit says the firearm was manufactured outside of the state of Illinois. Magistrate Judge Jonathan E. Hawley signed the complaint, sworn by telephone.

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1:21-mj-06156-JES-JEH #1 P 1 of 4
m age * 0 E-FILED

Thursday, 30 September, 2021 08:26:51 AM
Clerk, U.S. District Court, ILCD
AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the SEP 97 2021
Central District of Illinois CLE R K OF court
STRIC
United States of America ) CENTRAL DisTRICT ony
v. ) OF ILLINOIS
) Case No. 21-MJ- ly {Aly
)
)
)
_ ALANTE MALIK JACKSON )
Defendant(s)
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 September 20, 2021 in the county of Peoria _ in the
Central District of Illinois , the defendant(s) violated:
Code Section Offense Description
Title 18 United States Code, defendant herein, having knowingly been previously convicted under the laws of the
Section 922(g) State of Illinois of a crime punishable by imprisonment for a term exceeding one
year, did knowingly possess in and affecting interstate and foreign commerce, a
firearm.

This criminal complaint is based on these facts:

See attached Affidavit

Mf Continued on the attached sheet. s/Kevin Brown

—
oplainant ’s signature

KEVIN BROWN, ATF

Printed name and title

Sworn and subscribed to me telephonically pursuant to Fed. R.

Crim. P. 41(d)(3) and Rule 4.1. A “7 L _
s/Jonathan E. Hawley
> Judge's signature
City and state: Peoria, Illinois Jonathan E. Hawley,United States Madistrate Judge

Printed name and title
1:21-mj-06156-JES-JEH #1 Page2of4

AFFIDAVIT
IN SUPPORT OF CRIMINAL COMPLAINT

I. Background
I, Special Agent Kevin Brown, (hereinafter “Your Affiant”), do hereby depose and
state the following:

1. Your Affiant is a Special Agent of the United States Department of Justice,
Bureau of Alcohol, Tobacco, Firearms and Explosives (hereinafter “ATF”). Your Affiant
has been a law enforcement officer since April 2009.

2. This affidavit is submitted in support of a criminal complaint alleging that
Alante Jackson violated Title 18, United States Code, Section 922(g) (Felon in
Possession of a Firearm).

3. Because this affidavit is being submitted for the limited purpose of
establishing probable cause in support of a criminal complaint, I have not included each
and every fact known to me in this investigation. I have set forth only the facts that I
believe are necessary to establish probable cause to believe that the defendant
committed the offense alleged in the complaint.

4. The statements contained within this Affidavit are based on: (a) my
personal participation in this investigation; (b) information provided to me by other
federal, state, and local law enforcement officers; (c) my training and experience and the

training and experience of other law enforcement agents with whom I have spoken.
1:21-mj-06156-JES-JEH #1 Page3of4

II. Summary

5. On September 20, 2021, Peoria Police Officers observed a black Dodge
Charger parked at a Shell gas station located at 1900 N. Knoxville Avenue, Peoria,
Illinois. The officers believed this vehicle to be the same Dodge Charger that Peoria
Police Officers have attempted to stop on more than one occasion due to the vehicle’s
involvement in shooting investigations. The Dodge Charger was believed to be stolen,
and at one point was observed by Peoria PD Officers with stolen Alabama license plates
affixed to the vehicle. As officers continued driving towards the Shell gas station, they
observed Alante Jackson exit the gas station carrying a backpack and approach the
Dodge Charger. As the officers drove into the parking lot, Alante Jackson looked at
their vehicle. After looking at the officer’s vehicle, Alante Jackson quickly got into the
Dodge Charger and fled eastbound on Nebraska Avenue at a high rate of speed.
Officers believed, and later confirmed, that Alante Jackson did not have a valid driver’s
license. Officers observed Alante Jackson’s direction of travel and followed along his
path when they located the black Charger stopped on the 600 block of Frye Street.
Officers observed Jackson exit the vehicle still carrying a backpack.

6. One officer pursued Alante Jackson on foot and observed that the
backpack now appeared to be open. Alante Jackson was apprehended and taken into
custody. The keys to the Dodge Charger, a cell phone and a backpack containing
Alante Jackson ’s personal property were located near his arrest location.

7. A witness approached a Peoria Police Officer and took him to the rear of a
residence along the flight path of Alante Jackson. The witness stated that she observed

2
1:21-mj-06156-JES-JEH #1 Page4of4

Alante Jackson running between houses, pause to throw something onto the roof of a
garage, and then continue running. The witness explained where Alante Jackson threw
the object. Officers utilized a ladder to climb on top of the garage that the witness
pointed out. Officers located a Glock, Model 23, .40 caliber pistol, SN: YDX010 on top of
leaves on the roof of the garage. The firearm appeared to have been recently placed on
the roof as it was not covered by leaves and did not appear to have any weathering.

8. Record checks indicate that Alante Jackson has been previously convicted
of a crime punishable by more than one year in prison.

9. The firearm possessed by Alante Jackson was manufactured outside of

the state of Illinois. s/Kevin Brown

Kevin & "Brown, Special Agent

Bureau of Alcohol, Tobacco, Firearms &
Explosives

Sworn and subscribed to me by telephone pursuant to Fed. R. Crim. P. 41(d)(3) and
Rule 41 this 27th day et September, 2021.

s/Jonathan E. Hawley

Jopdthan E. Hawley ee
nited States Magistrate Judge

Peoria, Illinois

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