United States District Court

WESTERN DISTRICT OF MISSOURI

WESTERN DIVISION
UNITED STATES OF AMERICA
v.
RENO DILLARD
[DOB: 06/12/1978]

18 U.S.C. 922(g)(1) and 924(a)(2)

NMT 10 Years Imprisonment
NMT $250,000.00 Fine
NMT 3 Years Supervised Release
Class C Felony
$100 Mandatory Special Assessment
CRIMINAL COMPLAINT
Case Number: 17-MJ-00008-SWH

I, the undersigned complainant being duly sworn, state the following is true and correct to the best of my
knowledge and belief:
On or about January 23, 2017, in the Western District of Missouri, the defendant, Reno Dillard, having
been convicted of a crime punishable by imprisonment for a term exceeding one year, did knowingly possess, in
and affecting commerce, a firearm, to wit:

a Taurus, Model PT738, .380 caliber pistol, bearing serial number: 51037B;

a Taurus, Model 709 Slim, 9mm pistol, bearing serial number: TIS59042;

a Colt, Model MKIV, .45 caliber pistol, bearing serial number: SF13447; and

a Mossberg, Model 500 AT, 12-gauge shotgun, bearing serial number: G748251,

which had been transported in interstate commerce, in violation Title 18, United States Code, Sections
922(g)(1) and 924(a)(2).
I further state that I am a Special Agent with the Bureau of Alcohol, Tobacco, Firearms and Explosives
and that this complaint is based on the following facts:
(See attached Affidavit)
Continued on the attached sheet and made a part hereof: Yes

No.

Case 4:17-mj-00008-SWH Document 1 Filed 01/24/17 Page 1 of 2

Tyree Koerner, Special Agent

Bureau of Alcohol, Tobacco, Firearms and
Explosives
Sworn to before me and subscribed in my presence,

Jan 24, 2017

Date

at

Kansas City, Missouri

City and State

HONORABLE SARAH W. HAYS

Chief United States Magistrate Judge
Name and Title of Judicial Officer

Signature of Judicial Officer

Case 4:17-mj-00008-SWH Document 1 Filed 01/24/17 Page 2 of 2

17-MJ-00008-SWH
AFFIDAVIT
I, Special Agent Tyree Koerner, being duly sworn, state the following:
I am a Special Agent with the Bureau of Alcohol, Tobacco, Firearms and Explosives
(ATF). I have worked in law enforcement for over 17 years, and for the past 8 years I have been
employed as a Special Agent with ATF. In the performance of my duties with ATF, I have
investigated and participated in numerous investigations involving federal firearm and narcotic
violations. This affidavit contains information necessary to support a finding of probable cause.
It is not intended to include every fact or matter observed by me or known by law enforcement.
The information provided is based on my personal knowledge and observation during the course
of this investigation, information conveyed to me by other law enforcement officials, and my
review of records, documents, and other physical evidence obtained during the investigation.
The facts to support a finding of probable cause are as follows:
1.
On November 10, 2016 a burglary was reported at Jay Jays Pawn & Jewelry (a
Federal Firearms Licensee) located in Gulfport, Mississippi, where 29 firearms were reported
stolen. After this burglary, between December 13 and 16, 2016, JBs Pawn located in Gulfport,
Mississippi, and Sams Jewelry located in Pascagoula, Mississippi, were broken into as well. Then
on December 17, 2016, a violent robbery occurred at Bills Pawn located in Jackson, Mississippi,
where three elderly men were found murdered. During the course of these investigations, area
investigators coordinated efforts to develop two primary suspects that were later discovered to
have ties to the Kansas City, Missouri metro area. On December 21, 2016, the two primary
suspects were apprehended in Junction City, Kansas.
2.
As the investigation continued to progress, information was developed that the
above two suspects brought a majority, if not all of the firearms stolen during the November 10,
2016 burglary to the Kansas City area. This investigation further revealed that on January 20,
2017, two of the stolen firearms were recovered in the Kansas City area. Subsequent to those
firearm recoveries, agents learned through cooperator interviews that in early December 2016,
Reno DILLARD (DOB: 06/12/1978) of 7705 East 127th Street, Grandview, Missouri, purchased
approximately 20 of those stolen firearms for $1,200 to $1,500.
3.
In an effort to recover the stolen firearms, on January 23, 2017, a federal search
warrant was issued out of the United States District Court for the Western District of Missouri for
DILLARDs residence of 7705 East 127th Street, Grandview, Missouri. On this same date at
approximately 5:30 p.m., the federal warrant was executed and DILLARD was taken into custody
at the residence. During the course of the residential search, some of the items recovered are as
follows:

Case 4:17-mj-00008-SWH Document 1-1 Filed 01/24/17 Page 1 of 4

a.
Taurus, Model PT738, .380 caliber pistol (serial number: 51037B) that was
loaded with six ammunition rounds was located under the master bedroom mattress.
b.
Taurus, Model 709 Slim, 9mm pistol (serial number: TIS59042) that was
loaded with seven ammunition rounds was located under the master bedroom mattress.
c.
One nylon pistol holster containing a 9mm pistol magazine, which was
loaded with seven ammunition rounds was located under the master bedroom mattress.
d.
Two Visa debit cards in the name of Reno DILLARD were located in the
master bedroom on a table next to the bed on the same side as the previously mentioned
firearms.
e.
Colt, Model MKIV, .45 caliber pistol (serial number: SF13447) that was
loaded with an extended drum magazine filled with 28 ammunition rounds was found in
the basement safe. This firearm was determined to be stolen from the November 10, 2016,
Jay Jays Pawn & Jewelry burglary in Gulfport, Mississippi.
f.
Mossberg, Model 500 AT, 12-gauge shotgun (serial number: G748251)
that was loaded with five ammunition rounds was found in the basement safe.
g.
Two individually wrapped bags that contained a green leafy substance
believed to be marijuana were found in the basement safe. Total weight of approximately
12 grams.
h.
Twenty-Two (22) individually wrapped bags that contained a green leafy
substance believed to be marijuana were found in the master bedroom closet. Total weight
of approximately 439 grams.
i.

A bullet proof vest that was found in the master bedroom closet.

j.
A glass jar that contained a green leafy substance believed to be marijuana
was located on a table next to the couch in the master bedroom. Total weight of
approximately 40 grams.
k.
Two .45 caliber ammunition rounds were located on top of a karaoke
machine next to the bed in the master bedroom.
l.
One ammunition box containing thirty-six (36) 9 mm ammunition rounds
were located in a drawer in the living room.
m.
Two documents bearing the name Reno DILLARD were located in a drawer
in the living room. This item was located in the same drawer as the box of ammunition
rounds.
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4.
In addition to the above items, when searching the basement safe, agents first noted
that the safe was locked. To keep from damaging the safe upon entry, DILLARD provided agents
with the code to unlock the safe. When the safe was opened and searched, agents located the two
firearms described above under subsections e and f. In addition to the firearms, located in the
safe was a bag that contained two small plastic bags of marijuana listed above under subsection
g. Also contained within this bag were two digital scales, a seed grinder, and plastic baggies
that are all used to package marijuana for sale. Lastly, located in the safe was $2,030 in U.S.
currency and a wallet that contained a credit card issued to Reno DILLARD. Video was taken of
the items and their recovery locations, but these items, with the exception of the two firearms and
the marijuana, were not recovered as evidence.
5.
While at 7705 East 127th Street, Grandview, Missouri, a formal interview was
conducted with DILLARDs long-time girlfriend identified as Sequoya Williams. During this
interview Ms. Williams stated the Taurus 9mm pistol listed above under subsection b belonged
to her. Ms. Williams said she knew the firearm was in the master bedroom but was unsure of the
exact location and stated that DILLARD may have moved it. When asked about any other firearms
in the house, Ms. Williams said there were none. When later confronted with information that
additional firearms were located, Ms. Williams changed her story to say there was another small
caliber pistol in the bedroom but would not elaborate on who owned the pistol or where exactly
the pistol was located. During the interview Ms. Williams was also asked about the safe.
Ms. Williams responded by stating that DILLARD received the safe as a Christmas gift.
Ms. Williams further said she was unsure what the safe contained and was adamant that she did
not know the code to unlock the safe. Lastly, during the interview Ms. Williams was asked to
clarify which side of the bed she and DILLARD sleep on. Ms. Williams confirmed that DILLARD
sleeps on the same side of the bed in the master bedroom where the two pistols were located under
the mattress.
6.
Upon completion of the search warrant, a formal interview was attempted with
DILLARD. During this attempt DILLARD requested an attorney and the interview ended.
7.
convictions:

A review of DILLARDs criminal history revealed the following felony

a.
August 2013 convicted of felony Driving While Intoxicated in the Jackson
County, Missouri District Court. Case number: 1216-CR00926-01.
b.
August 2013 convicted of Distribution of a Controlled Substance and
unlawful Use of a Loaded Firearm by an Intoxicated Person in the Jackson County,
Missouri District Court. Case number: 1216-CR01785-01.
c.
August 2013 convicted of another count of felony Driving While
Intoxicated in the Jackson County, Missouri District Court. Case number: 1216-CR190701.

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8.
As a result of the above investigation, it has been determined that the felony
convictions listed in Reno DILLARDs criminal history prohibit him from possessing a firearm
that has traveled in interstate or foreign commerce, which is a violation of federal law, Title 18,
United States Code, Section 922(g)(1). A verbal interstate nexus determination of all the above
recovered firearms was requested through ATF Special Agent Steve Gravatt, a Special Agent
trained as an interstate nexus expert for the ATF. SA Gravatt stated that all the firearms were
manufactured outside the State of Missouri and would have traveled through interstate or foreign
commerce.
9.
In addition, based upon the firearms and marijuana being recovered within close
proximity to U.S. currency and marijuana packaging items, as well as some of marijuana being
packaged for sale, it is this Affiants belief that Reno DILLARD possessed a firearm in connection
with a drug trafficking crime. Therefore, DILLARD is in violation of federal law, Title 18,
United States Code, Section 924(c) carrying, using, or possessing a firearm in connection with a
crime of violence or drug trafficking crime.
Further, affiant sayeth not.

Tyree J. Koerner, Special Agent

Bureau of Alcohol, Tobacco, Firearms and
Explosives

24th day of January, 2017.

Subscribed to and sworn to before me this ______

HONORABLE SARAH W. HAYS

Chief United States Magistrate Judge
Western District of Missouri

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