Motion for Pretrial Detention and Hearing — United States v. Jerome Williams, No. 4:22 MJ 8129 SRW (Dkt. 4, E.D. Mo.)

Summary

The United States asks the Eastern District of Missouri to order Jerome Williams detained pending trial in No. 4:22 MJ 8129 SRW, and to hold a detention hearing at the initial appearance. The motion, signed by Assistant United States Attorneys Nathan Chapman and Angie E. Danis for United States Attorney Sayler A. Fleming, says the charge is destruction of evidence to obstruct a federal investigation, punishable by no more than 20 years, with no presumption of detention. It states that the offense involves the destruction of evidence relative to a murder, that the government believes the homicide of T.A. was planned, and that Williams is on supervised release after serving 420 months for kidnapping resulting in death, with release in 2021. The government argues that Williams is a serious flight risk and that no conditions would reasonably assure the safety of the community.

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION

UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
V. ) No. 4:22 MJ 8129 SRW

JEROME WILLIAMS, )
)
Defendant. )
)
MOTION FOR PRETRIAL DETENTION AND HEARING

Comes now the United States of America, by and through its attorneys, Sayler A. Fleming,

United States Attorney for the Eastern District of Missouri, and Nathan Chapman and Angie E.

Danis, Assistant United States Attorneys for said District, and move this Comt to order the

defendant detained pending trial, and fmther requests that a detention hearing be held at the time

defendant's initial appearance before the United States Magistrate Judge pursuant to Title 18,

United States Code, Section 3141, et. seq., and per cunent guidance from the Comt.

As for its grounds for detention, the government requests this Comt to consider the

following factors pursuant to Title 18, United States Code, Section 3142.

Presumption of Detention

1. The defendant is charged with destruction of evidence to obstruct a federal

investigation. This is an offense for which the statutorily mandated punishment is no more than

20 years imprisonment, but there is no presumption of detention in this matter.

The Nature and Circumstances of the Offense

2. Title 18, United States Code, Section 3142(g) requires this Comt to consider the

nature and characteristics of the offense charged, including whether the offense is a controlled

substance offense or a crime of violence. The instant charge is not considered a crime of violence,
•
but as evidenced in the Complaint Affidavit, the instant offense involves the destruction of

evidence relative to a murder.

The Weight of the Evidence Against the Defendant

3. Section 3142(g)(2) requires this Court to consider the weight of the evidence

against the defendant. The government submits that the evidence against the defendant is strong

and relies on the facts as aiticulated in the Complaint Affidavit in reliance on same.

The History and Characteristics of the Defendant

4. The defendant is cmTently on supervised release after having served 420 months in

the Bureau of Prisons for charges of kidnapping resulting in death. He was released in 2021.

The Nature and Seriousness of the Danger to the Community

5. The defendant engaged in the destrnction of direct evidence of the murder of T.A.

Fmthermore, given how briefly T.A. was in St. Louis prior to being murdered (less than one hour

after his flight landed), the Government believes that this homicide was planned.

Risk of Flight

6. There a serious risk that the defendant will flee because she is facing a significant

sentence in this case, based on the severity of the charges and his alleged role in the offense and

fmther potential charges relating to the homicide of T.A.

Conclusion

7. The government submits that when considering all of the factors outlined in Title

18, United States Code, § 3142(g), the factors weigh heavily in favor of detention. There is clear

and convincing evidence that no condition or combination of conditions that will reasonably assure
the safety of any other person and the community as well as the appearance of the defendant.

Respectfully submitted,

SAYLER A. FLEMING
United States Attorney

Isl Nathan Chapman
NATHAN CHAPMAN, #60978MO
ANGIE E. DANIS, #64805MO
Assistant United States Attorneys

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