STATE OF INDIANA

COUNTY OF ST. JOSEPH

STATE OF INDIANA

VS

IN THE ST. JOSEPH SUPERIOR COURT

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CAUSE NUlvIBER. 71DOl-1608-F5-000.!1~

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CAR'NELL TRASS
DOB:_999

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INFORMATION IN THREE COUNTS: .

COUNT I:
CARRYING A HANDGUN WIO A LICENSE
A LEVEL 5 FELONY
. COUNT II:
RESISTING LAW ENFORCEMENT
A CLASS A MISDEMEANOR
COUNT III:
BATTERY RESuLTING IN BODILY INJURY
A CLASS A MISDEMEANOR

COUNT I
AMY S CRESSY, upon information and belief, affirms under penalty of perjury that:
On or abou! August 24, 2016 in St. Joseph County, State of Indiana, Car'nell Trass.did knowingly
carry a handgun in or upon the defendant's vehicle or person without .~.license in the defendant's
possession while on orin school property, to-wit: Riley High School located at 1902 S. Fellows Street,
South Bend, Indiana.
All Qfwhich is. contrary to the form of the statutes in such cases made and provided by I.e; 35-47-2-1
and I.C. 35-47-2-1(e)(l), and against the peace and dignity of the State ofIndiana.
COUNIII
AMY S CRESSY, upon information and belief, affirms under penalty of perjury that:
On_or about August 24, 2016 in St. Joseph County, State of Indiana, Car'nell Trass did knowingly flee
from Wl1liam Jolmson,a law enforcement officer with the South Bend Police Department, after said
officer identified himself by visible or audible means and ordered Car'nell Trass to stop.
All of which is contrary to the form of the statutes in such cases made andprovid~d
35-44;1-3-l(a)(3),

and againstthe peace and dignity of the State ofIndiana.

by I.C ..

COUNT ill
AMY S CRESSX upon information and belief, affmns under penalty of perjury .that:
On or about August 24, 2016 in St. Joseph County, State of Indiana, Carnell Trass did knowingly. or
intentionally touch Collan Walton in a rude, insolent, or angry manner resulting in bodily injury ..
All of which is contrary to the form of the statutes in such cases made and provided by I.C.
35-42-2-1(c)(I) and I.C. 35-42-2-1 (d)(l), and against the peace and dignity of the State ()flndiana.
I affirm under the penalties for perjury that the foregoing representations are true.

m.,,-Aiy-~-..-

DEPUTY PROSECUTING ATIORNEY

Probable cause found. Arrest warrant ordered issued. Bond set at $
Corporate surety or $~

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day of August, 2016, at

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cash in lieu thereof, so found this day the

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E~ ST. JOSEPH SUPERIOR COURT

WITNESSES:
William Johnson South Bend Police Department
. Collan Walton
Sgt. Joseph Galea, SBPD
Principal Bayingana
.South Bend School Corporation Representative
South Bend Police Oepartment Uniform Patrol Officers
South Bend Police Department.Crime.Lab personnel
. All witnesses listed in police, medical and laboratory reports

III

STATE OF INDIANA
ST. JOSEPH COUNTY

FILED
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St Joseph

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CAUSE NO. 71DOJ:'''o~-f-S--oDO

STATE OF INDIANA
VS.
CAR'NELL D. TRASS
DOB~999

ST. JOSEPH SUPERIOR COURT

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SUPPLEMENATAL AFFIDAVIT IN
SUPPORT OF PROBABLE CAUSE

Amy S. Cressy affirming under the penalties for perjury, states that:
I am a Deputy Prosecuting Attorney in and for the 60th Judicial Circuit, St. Joseph ..
County, State of Indiana, and make this affidavit after reviewing verified South Bend
Police Department reports which were submitted to me.
On or about August 24,2016, Officer William Jolmson of the South Bend Police
Department was contacted by Collan Walton, a security officer at Riley High School
located at 1902 S. Fellows Street, South Bend, Indiana.
Mr. Walton advised Officer Johnson that multiple students had come forward
regarding another student brandishing a handgun and/or threatening to shoot them as they
walked to and from school.
Officer Johnson met with multiple students in the school office. These students
gave enough information for Officer Johnson and Mr. Walton to believe they needed to
speak with CAR'NELL D. TRASS.
Mr. Walton escorted !RASS from to the school office. He asked TRASS to place
his book bag on a table. When Mr. Walton grabbed the book bag and the zipper, TRASS
became confrontational. TRASS began to argue and Mr. Walton advised that the book
bag would be searched. Officer Johnson attempted to explain the complaints and the need

for school security to search the book bag. TRASS then got outofhis

chair and ran to the

door.
Mr. Walton attempted to grab TRASS. TRASS wrestled with Mr. Walton and
both went through the doorway. TRASS then pushed Mr. Walton doWn. (Mr. Walton was
later treated by the school nurse for an injury to his chest.)
Officer Johnson attempted to grab TRASS but TRASS was able to get away.
TRASS then ran through the front doors of the school. Officer Johnsonpursued

TRASS

on foot. Officer Johnson yelled for TRASS to stop several times but TRASS continued to
flee. Officer Johnson continued to chase TRASS as he ran westbound.
Officer Johnson called out the pursuit over the radio and communicated
TRASS'
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description and home address of~.

Calvert Street to other officers. Officer Johnson

continued to chase TRASS ~l the way to."

Calvert Street. He observed a woman,

later identified as TRASS' mother Carmen Gates, refuse to let TRASS into the residence.
TRASS then jumped onto a red bicycle and fled between houses.
Officer Johnson stayed with Ms. Gates. Other officers located TRASS who was .
hiding in what appeared to be a chicken coop behind.

E. Calvert Street.

.-. .. Mr. Walton and Principal Bayingana searched the book bag and located a loaded
.45 black Glock semiautomatic handgun along with some papers bearing the name
CAR'NELL TRASS. Officer Johnson went back to Riley High School where he retrieved
the book bag and the handgun, holster and ammunition.
TRASS and Ms. Gates were transported to the South Bend Police Department
Detective Bureau. Ms. Gates and TRASS were given time to speak privately. After

having the opportunity to speak privately, Ms. Gates and TRASS were advised of their
Miranda rights. They agreed to speak with Officer Johnson.
TRASS stated that he had the gun because a girl claimed he had gotten her
pregnant and was scared of her older brother. TRASS stated that he did not brandish the
handgun nor threaten to shoot anyone.

All of the above-listed events occurred in St. Joseph County, Indiana.

I affirm, under the penalties for perjury, that the foregoing representations are true

TING ATTORNEY