Case 2023CF000675 Document 2 Filed 04-18-2023 Page 1 of 11

FILED
04-18-2023
Clerk of Circuit Court
Brown County, WI
STATE OF WISCONSIN CIRCUIT COURT BROWN COUNTY
2023CF000675
BRANCH
Honorable Donald R.
Zuidmulder
STATE OF WISCONSIN DA Case No.: 2023BR000660
Plaintiff, Assigned DA: David L. Lasee Branch 1
Agency Case No.: 22-039140
vs. Court Case No.: 23CF

MATTHEW D. KNUTSON
DOB: /1982
Sex/Race: M/W
Eye Color: Green
Hair Color: Brown
Height: 5 ft 11 in
Weight: 205 lbs CRIMINAL COMPLAINT

Defendant. For Official Use

Complainant, David L. Lasee, Brown County District Attorney, being first duly sworn on oath,
deposes and says that:

Count 1: NEGLIGENT OPERATION OF VEHICLE

The above-named defendant, on or about Tuesday, November 23, 2021, in the City of
Green Bay, Brown County, Wisconsin, did endanger the safety of RS, by a high degree
of negligence, in the operation of a vehicle, not upon a highway as defined in sec.
340.01, contrary to sec. 941.01(1) Wis. Stats., a Class A Misdemeanor, and upon
conviction may be fined not more than Ten Thousand Dollars ($10,000), or imprisoned
not more than nine (9) months, or both.

Count 2: MISCONDUCT/OFFICE-FRAUD/RECORD/STATEMENT

The above-named defendant, on or about Tuesday, November 23, 2021, in the City of
Green Bay, Brown County, Wisconsin, in the officer's or employee's capacity as such
officer or employee, makes an entry in an account or record book or return, certificate,
report or statement which in a material respect the officer or employee intentionally
falsifies, contrary to sec. 946.12(4) Wis. Stats., a Class I Felony, and upon conviction
may be fined not more than Ten Thousand Dollars ($10,000), or imprisoned not more
than three (3) years and six (6) months, or both.

Complainant is the District Attorney with the Brown County District Attorney’s Office and knows
of the above offenses on information and belief based upon:

PROBABLE CAUSE:

The complainant, being duly sworn on oath, swears that he has had the opportunity to review
the police reports from Detective Breider the Brown County Sheriff’s Office, as well as audio
and video recordings from the Green Bay Police Department and other documents supporting
this complaint referenced herein, which are the types of reports and documents kept in the
 Case 2023CF000675 Document 2 Filed 04-18-2023 Page 2 of 11

ordinary course of business, which complainant believes to be truthful and reliable because
they have proven to be truthful and reliable on numerous occasions in the past.

The complainant further asserts that based upon his review of the referenced reports and/or
supporting documents, the incidents alleged occurred in the City of Green Bay, Brown County,
Wisconsin.

1. Complainant reviewed a police report authored by Officer Matthew Knutson of the Green
Bay Police Department. In that report, Knutson stated verbatim (emphasis added to relevant
portion):

On November 23, 2021, at approximately 6:12 p.m., while on patrol in the City of Green Bay in
unmarked squad 80 and in full uniform as 1T3, I was traveling south on Bader St and stopped
for the stop sign at Manitowoc Rd. The intersection of Manitowoc/Bader has stop signs for both
directions of Bader St and no traffic control signal for the traffic on Manitowoc Rd.

I observed a dark Tacoma truck approaching from the east. What drew my attention to this
vehicle specifically was that the vehicle opposite of my squad going north on Bader St at the
stop sign, pulled out from the stop sign directly in front of the vehicle. The vehicle had been
stopped and as the Tacoma approached, pulled out in front and began going across the
intersection to the north at a very slow speed (considering how close the oncoming vehicle
was approaching). The Tacoma had to lock up its brakes and come to a stop in order to avoid
a T style collision. At that point the tan Camry license plate continued south on Bader.
I immediately activated my emergency lights and conducted a U turn when all other vehicles
had stopped. As I got turned around facing northbound, I observed the Camry accelerate and
turn westbound onto Richmond St.

I called out with a traffic stop and based upon the behavior of the driver, it appeared he was
going to try and flee. This is a dead-end short road and I notified dispatch he was going to bail.
As the vehicle got to the dead end and pulled into the driveway of 2058, the driver exited and
began running to the south. He had on a large, baggy style shiny blue jacket and jeans. He
appeared Hispanic or native American with a bald head. I saw as he ran south and then heard
large barking dogs behind the address he was seen at (2069 Manitowoc Rd). I did not initially
chase the male into the address of 2059 Manitowoc as I could hear the dogs and there were
several of them and they sounded aggressive when the subject who fled ran into their yard.

I conducted a quick search of the vehicle and verified there were no other passengers or
weapons in plain sight. I observed there was a disabled vehicle placard affixed to the rearview
mirror. I could clearly tell the male who ran did not appear to be disabled and suspected the
vehicle might be stolen.

Prior to this traffic stop, I had just driven past Ofc Ainsworth. She was positioned to the south
on Bader just north of Imperial Lane. I notified her that the male was running right towards
where she was. I then heard her calling out updated locations and saying the man kept
reaching his hands into his pockets (signifying to other law enforcement that he is or potentially
could be armed). I then heard her in a very distressed tone ask where the next unit was as she
needed someone at Manitowoc/Lime Kiln. At that point I had verified nobody else was in the
vehicle and was concerned for her safety as it was unknown how long until the next officer

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would take to arrive. She then updated and said she was running back south towards Imperial
Lane.

I got back into my squad and drove south on Bader. I observed a white sedan that was ahead
of me at Bader/Imperial. I had to slow down to clear that intersection and drive around that
vehicle. As soon as I got around the vehicle, I observed Ofc Ainsworth chasing the same male
that had initially run from my traffic stop. She had her taser out and I could see that the taser
had already been deployed but was ineffective, as the wires were out of the control unit and
the male was not responsive to it and still running away. She had also stated on the air that he
pulled the probes out.

As the male was running south, it appeared he was going to run into the back part of
2084 Imperial Lane. 2084 Imperial Lane is a large apartment complex with a narrow
driveway that leads to the other complex, 2088 Imperial. The male began running up the
driveway about middle or on the eastern half of the driveway. I started to pull my vehicle
up on the western side of the driveway in order to get my vehicle out of the roadway
(due to the other vehicles already on Imperial Lane) and then exit it and in order to
attempt to take the male into custody. My window was open, and I yelled "get on the
ground" or something to that effect.

As I accelerated to go up the slight incline at 2084 and pull into the grassy part of the
front of the complex, the male then abruptly turned from the direction it appeared he
was heading and instead ran to the west, cutting directly in front of me and causing me
to make contact with the rear of his right leg on the front left corner of my squad. The
speed of my squad is estimated at <5mph. The contact caused between my vehicle and
the male was unintentional. It caused him to fall initially, but then get up and start
running away again. As he got up and started running, I was able to exit my vehicle and
get up to him. I could not see his hands, as they were in front of his torso as he was
running away. His body was at an awkward position, where he was leaning forward as
he was running, and I used his body being off balance and off center to decentralize him
using two hands to push him on his back flat onto his stomach and chest and onto the
grass. From that position, I was able to get his hands behind his back and into
handcuffs.

The male was searched and found to be in possession of a rifle round that had no primer
(believed to be an ornament on his keychain). There were no other weapons or contraband
located on his person. He said his leg (left) hurt from running but was not injured from
either being tased by Ofc Ainsworth or from the contact with my squad, or from getting
him into custody. He was out of breath and said he had difficulty breathing (as is expected
from running several blocks). He was secured in the rear of my squad vehicle where he told
Sgt Hock numerous times that he "just wanted to go to jail" and refused any rescue or medical
treatment. He verbally identified himself as [RS, an adult male] and found to have numerous
warrants.

While in the rear of my squad I asked [RS] if he would submit to a PBT. He refused. Sgt Hock
said he didn't smell any odor of intoxicants, but that he was exhibiting signs of possible drug
induced impairment. After several minutes trying to catch his breath, [RS] became periodically
unresponsive. Sgt Hock requested an ambulance for medical treatment and transportation to
the local hospital due to these signs he was exhibiting.

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I inspected my squad and squad 80 had no damage on it. [RS] had no answer as to why he
ran from police other than "he was scared." DOT records show that [RS]'s license is revoked
due to prior OWI relate offenses. Based upon that in addition to his driving behavior which
nearly caused a substantial crash at the intersection of Bader/Manitowoc Rd, I completed
citations for failure to yield right of way from a stop sign and OAR-circuit.

Green Bay Metro Fire Department personnel transported [RS] to Aurora Baycare hospital for
medical treatment. Following medical clearance, he was transported to Brown County Jail and
issued citations for resisting an officer as well as his traffic violations.

I completed an use of force report for my decentralization of [RS] onto the grass in front of
2084 Imperial Lane. The vehicle had no other occupants and other officers verified that it did
not belong at 2058 Richmond St. It was towed by Heavy Duty towing. I typed my details.

2. During the pendency of the criminal case filed against [RS], Complainant reviewed a letter
that was written by defense counsel for [RS] which was sent to the assigned prosecutor for
[RS]’s criminal case. The relevant portion of that letter indicated the following:

“Additionally, I wanted to bring to your attention the actions of Green Bay Police Department
Officers in 21CM1074. Specifically, the actions of Officer Matthew Knutson. You will find in
his report that he describes him hitting [RS] with his squad car at the last second and other
vehicles being in the road. The squad camera footage tells a different story.

Specifically, at time stamp 3:40 of file AXON_Fleet_2_Video_2021-11-23_1812, one can see

Officer Knutson turn right and pass a vehicle in the intersection on the left side of the road.
[RS] is traveling across the road and is fully illuminated in Officer Knutson’s headlights. There
is no other vehicle in the roadway in front of Officer Knutson’s right-to-left and headed towards
a driveway.

As [RS] travels in his straight path across the grass of the lawn, Officer Knutson yells out the
window of the vehicle for [RS] to get on the ground at 3:46. Officer Knutson then accelerates
over the curb onto the grass and strikes [RS] with the front left of his squad car. There was no
need for Officer Knutson to drive on the grass as there was no other vehicle in the driveway at
the time. This knocks [RS] to the ground, and after a moment he attempts to get up and hobble
away, at which point Officer Knutson tackles him to the ground. [RS] would complain of leg
pain after his arrest, understandable considering the fact that he was struck by a vehicle that
hopped a curb and drove on the grass, and would eventually be transported to a local hospital
to be evaluated after experiencing some shortness of breath and leg pain.

More troubling, was the fact that Officers on scene seemed to think that [RS]’s plight was funny
and a (sic) something to laugh about. Specifically, at the time stamp of 8:13 in the file
AXON_Body_3_Video_2021-11-23_1813_X6033785F, Officer Knutson, after placing [RS] in
the rear of the squad car, can be seen mimicking [RS] hobbling after being struck by Officer
Knutson’s squad car to the laughter of the other officers on scene.”

The assigned prosecutor reviewed the letter, and then viewed the squad video referenced in
the letter, the report filed by Knutson, and other reports and videos from the incident on
November 23, 2021. That assigned prosecutor alerted Complainant, who reviewed the same

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materials, and immediately had concerns about Knutson’s conduct and the veracity of the
police report produced by Knutson.

Complainant would further note that Officer Knutson prepared and submitted a Use of Force
Sheet for this incident, which Complainant knows is standard practice when an officer from the
Green Bay Police Department uses force while apprehending a suspect. The Use of Force
Sheet contains no mention of Knutson striking [RS] with his squad car, further indicating
Knutson’s intention to suggest that he struck [RS] with the squad car accidentally, which
appeared wholly inconsistent with the squad video.

Complainant then alerted members of the command staff at the Green Bay Police Department
about the incident. Complainant believes that command staff members then viewed the reports
and the available squad camera and body camera footage, and the decision was made to refer
the matter to the Brown County Sheriff’s Office so that an outside agency could conduct an
investigation into potential criminal conduct on the part of Knutson.

3. Complainant has also reviewed a report prepared by Det. Breider of the Brown County
Sheriff’s Office who was tasked with conducting an investigation into the incident to determine
any potential criminal wrongdoing on the part of Knutson, a relevant portion of that report
includes a description of Detective Breider’s review of the squad camera and body camera
footage of the incident:

OFFICER MATT KNUTSON SQUAD CAMERA

Officer Knutson's squad video begins on 11-23-21 at 6:12pm. Officer Knutson's squad car is
on Bader St. southbound approaching Manitowoc Rd. Officer Knutson stopped at this
intersection. A stopped vehicle is facing him northbound on Bader St. This vehicle begins to
drive forward through the intersection. A vehicle heading east on Manitowoc Rd. is forced to
abruptly stop to avoid striking the passenger side of the vehicle that had entered the
intersection.

Officer Knutson activated his squad emergency lights and then completes a U-turn in the
intersection. Officer Knutson is now behind the driver that committed the traffic violation.
Footage shows the brake lights are activated on this car and it then makes a left turn onto
Richmond St. The squad car acceleration is heard on the footage and the squad emergency
lights are still activated.

Officer Knutson makes a left turn onto Richmond St. The above vehicle is seen entering a
driveway at the end of this dead-end road. The driver of this car stops at an angle at the end of
this driveway, partially into the grass. The driver opens the vehicle driver's side door and then
begins to run south. The driver is a male with blue jeans, a dark top, and is bald.

Officer Knutson begins to exit his car as he yells, "get back in the car." Officer Knutson radios
that the suspect is running south toward "you." Officer Knutson knew Officer Ainsworth was in
the area. Officer Knutson approaches the car and does a glance inside before moving in the
direction the suspect had run. Officer Knutson provides a suspect description over the radio.
Officer Knutson leaves the area of the car and goes out of camera range. There is yelling
heard on the footage, but I cannot hear what is being said. Officer Knutson comes back into
camera view. A female voice is heard on the radio, and it sounds like she is giving locations of

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the fleeing suspect. Her voice is heard stating that "he" is walking around a yard with his hands
in his pockets. As this is happening, Officer Knutson searches the suspect car.

A female voice can be heard asking for additional units at intersections. Officer Knutson
returns to his squad and proceeds east on Richmond St. and south on Bader St. His squad
emergency lights are still activated. He proceeds through the intersection of Manitowoc Rd.
and heads south toward Imperial Ln. At 3 minutes 39 seconds, Officer Knutson approaches
the rear of one car at Bader St. and Imperial Ln. He slows and goes around this car as he
turns westbound on Imperial Ln. He accelerates after going by this car and there are no other
vehicles visible on Imperial Ln. in front of the squad. The suspect is immediately in camera
view running southwest, diagonally, across Imperial Ln. toward the entrance to an apartment
complex. Officer Knutson slowed. The male does not look back at the squad. His right arm is
swinging as he runs. It appears that his left hand is stationary against the left side of his body.
Both hands are visible as the suspect enters the apron to the driveway leading to the
apartment complex parking lot. The male does not appear to have anything in his hands.

Officer Knutson yells for the driver to get on the ground and the male runs west across the
apron toward the grass. The male still does not look back. Officer Knutson's squad appears to
proceed up the apron incline from the road to the apartment complex parking lot. The male is
past this incline and entering the grass. At 3 minutes 47 seconds, the front driver's side of
Officer Knutson's squad contacts the back of the male. A squad speed was not visible on the
camera footage just prior to and during squad contact with [RS]. The male goes down in front
of the squad and momentarily is out of camera view. Officer Knutson stops the squad. The
male gets back up and tries to run toward an apartment complex. Officer Knutson approaches
the male from the rear, and he uses both hands to push the back of the male, at which time the
male falls forward on to the ground. A female officer runs up to assist Officer Knutson. It
appears that the male is on the ground as these two officers effect an arrest.

Other officers arrive to assist. [RS] is escorted to the rear of Officer Knutson's squad. Audio
indicates [RS] sits in the back of the squad. Officer Knutson can be heard telling [RS] he is
"fine", and he is not hurt, and he is not "that old".

Sgt. Hock begins to speak with [RS]. This conversation is documented in the documentation of
the back seat squad camera footage

OFFICER KNUTSON BODY CAM

Officer Knutson's body cam shows him getting out of his squad when [RS] runs from the car he
had been operating. Officer Knutson yells for him to get back in the car and then he radios to
(Officer Ainsworth) that [RS] is running toward her. Officer Knutson provides a suspect
description over the radio. He states the suspect is a male Hispanic, blue shirt, blue pants.

Officer Knutson enters the backyard of the residence where the suspect car stopped. He
begins to yell, "come here now." A male voice is heard saying he is not the suspect and that he
is just out with his dog. This same male said the suspect jumped a fence. Officer Knutson
returns to the suspect vehicle and does an examination of the inside of the car.

Officer Knutson runs back to his squad and footage shows the dashboard of his squad as he
drives toward Imperial Ln.

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The squad stops and Officer Knutson yells, "get on the ground." Footage shows his driver's
side window open. He exits his car and approaches the front of his squad where [RS] is now
up on his feet. Officer Knutson pushes [RS] to the ground and instructs him to put his arms
behind his back. [RS] is laying on his stomach. Another officer arrives to assist in the arrest.

[RS] says he cannot breathe. Officer Knutson asks for his name, and he says [RS]. Officer
Knutson asks why he ran, and he said he was scared. Officer Knutson asks why he is scared
but [RS] has difficulty answering because he is breathing heavy. Officer Knutson says, "catch
your breath."

Officer Knutson says, "You are not injured. Ok, I pushed you to the ground, you are not
injured." [RS] responds, "I know." Officer Knutson asks [RS] for his date of birth, and he
responds. Officer Knutson asks about the car and also asks him again about why he ran. He
repeats he was scared.

Officer Knutson tells him he has a warrant and shell casings. [RS] tells Officer Knutson the
shell casing is a keychain.

Officer Knutson said to [RS], "So when you ran into my car, you didn't hurt anything did you?"
[RS] shakes his head no. Officer Knutson documented in his report that, "He said his leg (left)
hurt from running but was not injured from either being tased by Ofc. Ainsworth or from the
contact with my squad." While I watched and listened to Officer Knutson's body camera
footage I did not hear [RS] say his leg hurt from running.

[RS] is assisted to his feet and escorted to Officer Knutson's squad where he is patted down
and then placed in the back of the squad.

[RS] lays down on his right side. Officer Knutson tells him he needs to sit up. Officer Knutson
says, "You're fine man" and "you're not hurt, you're not that old." Officer Knutson and another
officer help him sit up.

A group of officers gather and start laughing.

Sgt. Hock starts talking to [RS].

OFFICER KNUTSON SQUAD BACKSEAT CAMERA

I viewed footage of [RS] in the backseat of Officer Knutson's squad car. He entered at around
6:20pm. [RS] is breathing hard and lays down right away. Knutson's comments are
documented above.

Sgt. Hock introduced himself. Sgt. Hock asked if he was okay, and he said no. Sgt. Hock
asked what was wrong and [RS] said, "my leg." Sgt. Hock asked if he needed rescue for his
leg and [RS] said no. Sgt. Hock asked if he pulled a muscle in his leg and [RS] said, "he hit me
with the vehicle." Sgt. Hock said, "vehicle?" and the tone of Sgt. Hock's voice suggests
surprise. [RS] repeated, "he hit me." Sgt. Hock said, "so you think he hit you with a car?" [RS],
"I know he did." Sgt. Hock spoke of the cameras and that the cameras would have recorded
that. [RS] responded "ok" and "thank you."

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Sgt. Hock asked [RS] to sit up, but he said his leg hurt. Sgt. Hock suggested they have rescue
respond and [RS] said no. Sgt. Hock asked [RS] if he wanted to go to the hospital and he said
no. [RS] was still breathing heavy.

Sgt. Hock said he was going to sit him up because he did not like him laying down. When he
sat him up, [RS] repeatedly said "oww." Sgt. Hock asked again what hurts and he said his leg.
Sgt. Hock said that he could either take him to the hospital or call an ambulance. [RS] asked to
be taken to jail. Sgt. Hock said he would not be taken to jail if his leg hurts. Sgt. Hock said that
if it hurts bad enough that he is not capable of sitting up, then he would have to go to the
hospital. [RS] repeated that he wanted to go to jail. [RS] sat up and cried out in pain. Sgt. Hock
asked if anything else happened and [RS] said no.

Sgt. Hock asked him about running from police and inquired about why he was scared. He
said his life was already "fucked up" enough. Sgt. Hock asked if he knew that he had warrants
for his arrest and [RS] said he knew he had one. Sgt. Hock asked if that is why he ran and he
said yes.

Sgt. Hock asked if his leg hurt from falling down and [RS] said, "he hit me with the vehicle."
Sgt. Hock said he would check the squad video, but he did not think that is what happened.
Sgt. Hock asked if anything else hurt and he said, "my hip on down." Sgt. Hock asked what his
hip hurt from, and he said, "from when he hit me."

The squad microphone picked up a conversation where it sounded like Officer Knutson said, "it
looked like he was going to run left, so I cut up, and then he frickin’ ran right in front of it and
then got up and started running again."

At 12 minutes 18 seconds, officers assisted [RS] in sitting up again and he was asked if he
now wanted an ambulance. He was coached through deep breathing to try to calm him down.
The back window was opened for him so he could get fresh air. At 14 minutes and 2 seconds
[RS] speaks to Knutson through a window. He says he knows he has been an asshole. Officer
Knutson said he has been fine since he has been in cuffs. Officer Knutson said if he would not
have ran he would have been arrested on the warrant and would not have been out of breath
and "your leg would not have hurt from running."

MULTICAM- BODY CAMERA AND SQUAD CAMERA

On 10-31-22, I used the multi-cam mode to watch Officer Knutson's body camera and squad
camera synced together. The body cam shows Officer Knutson manipulating the squad
steering wheel. It shows the steering wheel turning right (clockwise) as the squad turns right
from Bader St. to Imperial Ln. Officer Knutson goes around one vehicle, and then travels
westbound on Imperial Ln., in the eastbound lane. [RS] is visible on camera crossing Imperial
Ln. Officer Knutson's steering wheel goes back to a straight position as Officer Knutson
proceeds west on Imperial Ln. He stays westbound in the eastbound lane. [RS] is seen
entering the apron to the apartment complex driveway. Officer Knutson steers hard left
(counterclockwise) as he initiates his left turn toward the apron at the parking lot entrance.
Officer Knutson then turns the wheel back to the right as he enters the apron. [RS] is now at
the front driver's side corner of Officer Knutson's squad car. Just prior to contact, Officer

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Knutson steers back to the left. Officer Knutson then steers slightly right and maintains that
steering wheel position until the front driver's side corner makes contact with the back of [RS].

REVIEW OF SQUAD CAMERA/OFFICER KNUTSON'S REPORT

In his report, Officer Knutson states, "The male began running up the driveway about middle or
on the eastern half of the driveway." This is consistent with what is seen on the squad camera.
Officer Knutson reported that, "I started to pull my vehicle up on the western side of the
driveway in order to get my vehicle out of the roadway (due to the other vehicles already on
Imperial Lane).The squad camera does not show any other vehicles on Imperial Ln., other
than the one he had passed.

Officer Knutson also documented, "As I accelerated to go up the slight incline at 2084 and pull
into the grassy part of the front of the complex, the male then abruptly turned from the direction
it appeared he was heading and instead ran to the west, cutting directly in front of me and
causing me to make contact with the rear of his right leg on the front left corner of my squad."
When I watched the squad camera footage, I did not observe an abrupt turn by [RS], nor did I
see [RS] cutting directly in front of Officer Knutson's squad car.

4. Complainant also reviewed a subsequent report from Detective Breider wherein

Detective Breider describes an interview he conduct with Officer Knutson on January 16, 2023.
Detective Breider’s report indicates that:

On the morning of January 16, 2023, Detective Breider met with Officer Knutson and his
attorney at the Brown County Sheriff’s Office. Knutson was allowed to watch the body camera
and squad camera footage of the incident from November 23, 2021, wherein Knutson struck
[RS] with his squad car.

After Knutson and his attorney had the opportunity to watch the footage from around 9:30am
until 11:10am, at which time they notified Detective Breider that Knutson was prepared to
speak with him.

Detective Breider then played Knutson’s squad video and body camera video again for
reference while speaking with Knutson. Detective Breider paused the squad camera at the
point where Officer Knutson left the traffic stop and traveled west on Imperial Ln. Detective
Breider explained that he wanted some clarification on things he documented in his report.
Detective Breider read verbatim from Knutson’s report, "The male began running up the
driveway about middle or on the eastern half of the driveway. I started to pull my vehicle up on
the western side of the driveway in order to get my vehicle out of the roadway due to the other
vehicles already on Imperial Lane." Detective Breider asked for clarification about the part that
referenced other vehicles already on Imperial Ln. Other than the one car he had already
passed, camera footage shows Imperial Ln. empty of any other vehicles, moving or parked.
Officer Knutson mentioned the vehicle he had already passed. He said that he was not sure if
it was his "flashing lights" or something that created a reflection at the dead end of Imperial
Ln., but he stated he "thought something else was there" in front of him on the roadway. It was
described as a reflective kind of thing that made him think a vehicle was coming toward him.

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Detective Breider read verbatim from his report, "As I accelerated to go up the slight incline at
2084 and pull into the grassy part of the front of the complex." He asked Officer Knutson to
explain what happened.

Officer Knutson said that when he saw [RS], he believed [RS] was going to run straight on the
left side of the driveway. Officer Knutson mentioned a building and woods in the back and his
thought process was that if somebody is running from the police, this is the direction they
would want to go. He stated he thought [RS] would stay on the pavement between a fence that
runs north south on the east side of the lot, and the building. Officer Knutson believed [RS]
was heading south through the lot and Officer Knutson committed to making a left turn into this
parking lot. Officer Knutson added that at this point [RS] was outside his window and he was
moving his squad off the road. Officer Knutson said, "in hindsight, I should have stopped the
vehicle right there and got out and gone after him."

Officer Knutson said, "when you break this down, there was not an oncoming vehicle coming
at me." Officer Knutson added that he had committed to getting his vehicle off the roadway. I
asked about his documentation that he pulled "into the grassy part". Officer Knutson stated
that [RS] was on one side and Officer Knutson stated, "I am going to go up and around him,
past him, you know get past him and turn into the other side of him." As Officer Knutson told
me this, he gestured with his hands as if [RS] was to the left of him and he was going to go
around the right of [RS]. Knutson’s attorney interjected asking Officer Knutson if he was going
to the right and he said yes. Detective Breider told Officer Knutson that when he viewed the
video, he did not see [RS] doing an abrupt direction change like he described in his report.
Officer Knutson said that once he committed to turning, his attention was now on one tree, and
then two trees in the grass area. He said he was also concerned about the whereabouts of
Officer Ainsworth. Officer Knutson stated that when his focus returned to [RS], [RS] was right
in front of the squad. Officer Knutson said he assumed that [RS] was on "this line and then cut
over on this line." When he verbalized this, he pointed his hands in the direction he thought
[RS] was going to go, and then pointed to the right as he described how he assumed [RS] cut
to the right prior to contact. Detective Breider asked Officer Knutson if he could understand
Detective Breider’s concern when Knutson describes an abrupt direction change, when in
Detective Breider’s opinion the footage shows [RS] running pretty straight. Officer Knutson
said he understood and stated that he thought [RS] was going left. Because [RS] ended up in
front of his squad, Officer Knutson stated that he made the assumption that [RS] cut back to
the right in front of his squad. Officer Knutson showed me on the footage where [RS]'s
direction was toward the windows on the side of the complex rather than south down the
paved portion where he thought [RS] was heading.

Detective Breider then addressed a sentence in Knutson’s report where he states, "He
(referring to [RS]) said his leg (left) hurt from running but was not injured from either being
tased by Ofc. Ainsworth or from the contact with my squad, or from getting him into custody."
After watching the footage, Detective Breider was unable to locate a time when [RS] said his
left leg hurt from running. Detective Breider asked Knutson if he remembered having a
conversation with [RS] where he said that his left leg hurt from running. Officer Knutson said it
was a "series of deductions". Officer Knutson described discussions with [RS] about what was
hurting and how Officer Knutson witnessed heavy breathing. Officer Knutson said it appeared
from [RS]'s ability to run and his ability to move his left leg in and out of the back of the squad,
that the contact with the squad was not the issue with his left leg. Officer Knutson said that his
"recollection" was that he thought [RS] got hit by the squad on his right side and [RS] said his

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 Case 2023CF000675 Document 2 Filed 04-18-2023 Page 11 of 11

left leg was hurting. Officer Knutson said he wondered why his left leg was hurting if he got hit
on his right side, so he thought it was likely from him running.

Detective Breider played the arrest process to confirm that [RS] did not make mention of left
leg pain prior to getting escorted to the squad. Officer Knutson then referred to something Sgt.
Hock said when he was talking to [RS] in the back of the squad. He believed the pain was
narrowed down to [RS]'s left leg during that conversation. Officer Knutson believed [RS]
referred to "this one" when Sgt. Hock asked which leg hurt, and [RS]'s left leg was outside the
car and indicated that was the leg that hurt.

Detective Breider then asked about the officers laughing and his stepping forward motion that
seemed to spawn the laughter. Officer Knutson said the act was stupid and inappropriate.
Officer Knutson said it had to do with the act of [RS] getting back up after being hit by the
squad and him trying to run with his pants falling down. Detective Breider asked Officer
Knutson if it had anything to do with the contact with the squad and he said no, it was what
happened right after.

Based on the foregoing, the complainant believes this complaint to be true and correct.

Subscribed and sworn to before me on Electronically Signed By:

04/18/23 David L. Lasee
Electronically Signed By: Complainant
Caleb J Saunders
Deputy District Attorney
State Bar #: 1094077

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