Indictment — No. 4:24-cr-00343 (Dkt. 2, E.D. Mo.)

Summary

An indictment filed July 3, 2024 as Doc. #2 in United States v. Samuel Davis and Michael Hill, No. 4:24CR343-SRC/JSD (Case 4:24-cr-00343-SRC), in the U.S. District Court for the Eastern District of Missouri. The general allegations state that both defendants were police officers with the Northwoods Police Department. Count One cites 18 U.S.C. § 241 and Count Two cites 18 U.S.C. § 242, each concerning acts on or about July 4, 2023 under color of law. Count Three cites 18 U.S.C. § 1512(b)(3) and Count Four cites 18 U.S.C. § 1519 against Davis, and Count Five cites 18 U.S.C. § 1001 against Hill.

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“Indictment — No. 4:24-cr-00343 (Dkt. 2, E.D. Mo.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-4-24-cr-00343-dkt-2-e-d-mo-32fb671d7a/, SHA-256 b28feb647743be933111f73af2cd3c92fa9f8d266141f09074f69c0ab1bfe714.

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Case: 4:24-cr-00343-SRC Doc. #: 2 Filed: 07/03/24 Page: 1 of 4 PageID #: 8

FILED
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI JUL - 3 2024
U. S. DISTRICT COURT
EASTERN DISTRICT OF MO
ST.LOUIS
UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
V. ) No.
)
)
SAMUEL DA VIS and ) 4:24CR343-SRC/JSD
MICHAEL HILL, )
)
Defendants. )

INDICTMENT

The Grand Jury charges that:

GENERAL ALLEGATIONS

At all times relevant to this Indictment:

1. The Northwoods Police Department (''NPD") was a law enforcement agency in the

Eastern District of Missouri;

2. Among other functions, the NPD was responsible for investigating cnmes

occurring in Northwoods, Missouri ;

3. Defendants SAMUEL DAVIS and MICHAEL HILL were employed by the NPD

as police officers;

4. Defendant MICHAEL HILL was defendant SAMUEL DAVIS ' s supervisor;

5. Defendants SAMUEL DAVIS and MICHAEL HILL were sworn to uphold the

United States Constitution, as well as the laws of the State of Missouri ;

6. On or about July 4, 2023 , Defendants SAMUEL DA VIS and MICHAEL HILL

encountered C.G. after responding to a call for service at a Walgreens in Northwoods, Missouri.
Case: 4:24-cr-00343-SRC Doc. #: 2 Filed: 07/03/24 Page: 2 of 4 PageID #: 9

COUNT ONE
[18 u.s.c. § 241]

7. Paragraphs 1-6 are incorporated here.

8. On or about July 4, 2023 , within the Eastern District of Missouri, the defendants,

SAMUEL DAVIS AND MICHAEL HILL,

while acting under color of law, did knowingly and willfully conspire and agree together and with

each other, to injure, oppress, threaten, and intimidate C.G. in the free exercise and enjoyment of

the right, secured and protected by the Constitution and laws of the United States, to be free from

unreasonable seizure by one acting under color of law, which includes the right to be free from the

use of unreasonable force by a law enforcement officer. The defendants' acts included

kidnapping.

In violation of and punishable under Title 18, United States Code, Section 241.

COUNT TWO
[18 u.s.c. § 242]

9. Paragraphs 1-6 are incorporated here.

10. On or about July 4, 2023 , within the Eastern District of Missouri , the defendants,

SAMUEL DA VIS AND MICHAEL HILL,

while acting under color of law and aiding and abetting one another, willfully deprived C.G. of the

right, secured and protected by the Constitution and laws of the United States, to be free from

unreasonable seizure, which includes the right to be free from the use of unreasonable force by a

law enforcement officer. Specifically, 1) defendant MICHAEL HILL instructed defendant

SAMUEL DA VIS to take C.G. to Kinloch, Missouri , which is outside the jurisdiction of the NPD,

and 2) defendant SAMUEL DAVIS then drove C.G. to a field in Kinloch, Missouri, where

defendant SAMUEL DAVIS physically assaulted C.G ., including by striking him with his police

baton, while C.G. was handcuffed and did not pose a threat to anyone. The defendants ' acts
Case: 4:24-cr-00343-SRC Doc. #: 2 Filed: 07/03/24 Page: 3 of 4 PageID #: 10

included kidnapping, involved the use of a dangerous weapon, and resulted in bodily injury to C.G.

In violation of and punishable under Title 18, United States Code, Section 242 .

COUNT THREE
[18 U.S.C. § 1512(b)(3)]

11 . Paragraphs 1-6 are incorporated here.

12. On or about July 4, 2023 , within the Eastern District of Missouri, the defendant,

SAMUEL DAVIS,

did knowingly engage in mislead ing conduct toward another person with the intent to hinder,

delay, and prevent the communication to a federal law enforcement officer and judge of

information relating to the commission and possible commission of a federal offense in the Eastern

District of Missouri, specifically, the offense of Deprivation of Rights under Color of Law, as

alleged in Count Two of this Indictment. That is, defendant SAMUEL DA VIS made a misleading

statement to a police dispatcher by falsely reporting that C.G. was " GOA" or "Gone on Arrival"

when defendant SAMUEL DAVIS responded to Walgreens in Northwoods, Missouri, on July 4,

2023 , after receiving a call for service related to C.G. This statement was misleading because, in

truth and in fact, defendant SAMUEL DAVIS knew that C.G. had been present at the Walgreens

at the time NPD arrived there because defendant SAMUEL DA VIS handcuffed C.G. at the

Walgreens and transported C.G. from the Walgreens to a field in Kinloch, Missouri .

In violation of and punishable under Title 18, United States Code, Section 1512(b)(3).

COUNT FOUR
[18 u.s.c. § 1519]

13. Paragraphs 1-6 are incorporated here.

14. On or about July 4, 2023 , within the Eastern District of Missouri, the defendant,

SAMUEL DAVIS,

acting in relation to and in contemplation of a matter w ithin the jurisdiction of the Federal Bureau
Case: 4:24-cr-00343-SRC Doc. #: 2 Filed: 07/03/24 Page: 4 of 4 PageID #: 11
) '

of Investigation, an agency of the United States, knowingly altered, concealed, covered up, and

falsified a record and tangible object with the intent to impede, obstruct, and influence the

investigation and proper administration of that matter. Specifically, defendant SAMUEL DA VIS

knowingly altered, concealed, covered up, and falsified an NPD record by turning off his

department-issued body worn camera before concluding his interaction with C.G.

In violation of and punishable under Title 18, United States Code, Section 1519.

COUNT FIVE
[18 u.s.c. § 1001]

15. Paragraphs 1-5 are incorporated here.

16. On or about July 13, 2023 , within the Eastern District of Missouri , the defendant,

MICHAEL HILL,

knowingly and willfully made a materially false, fictitious , and fraudulent statement in a matter

within the jurisdiction of the executive branch of the Government of the United States, to-wit:

defendant MICHAEL HILL falsely told Federal Bureau oflnvestigation Special Agents who were

investigating a civil rights violation within their jurisdiction that, on July 4, 2023 , C.G. requested

to go to Kinloch, Missouri by stating that C.G. "had people" in Kinloch, when defendant

MICHAEL HILL knew that C.G. had not made any such statement and thus defendant MICHAEL

HILL knew that his statement to the FBI was false.

In violation of and punishable under Title 18, United States Code, Section 1001(a)(2).

A TRUE BILL.

FOREPERSON
SAYLER A. FLEMING
United States Attorney

CHRISTINE KRUG
Assistant United States Attorney

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