U.S. Attorney’s Office Will Not Pursue Criminal Civil Rights Charges in Death of Adams County Rancher
BOISE – The U.S. Attorney’s Office for the District of Idaho announced today that there is insufficient evidence to pursue federal criminal civil rights charges against Adams County deputy sheriffs Cody Roland and Brian Wood for the death of Jack Yantis on Nov. 1, 2015.
Earlier today, the U.S. Attorney’s Office notified Mr. Yantis’s family, through their attorney, of this decision.
Federal authorities conducted a comprehensive and independent investigation of the events surrounding the death of Mr. Yantis, who was shot on Highway 95 near Council, Idaho, as he attempted to assist the deputies with his injured bull. The bull had been struck by a car and the accident drew the deputies, medical personnel and Mr. Yantis to the scene. The independent investigation included a review of the materials and evidence gathered by the Idaho State Police, including reports of the thorough investigation of the shooting scene; forensic reports detailing the scientific examination of physical evidence, such as gunshot residue and ballistics evidence; the autopsy report of Mr. Yantis; the necropsy report of the bull; interviews of emergency responders and travelers present at the time of the shooting; interviews with two civilian eyewitnesses who witnessed the shooting; multiple interviews with Roland and Wood; the 911 calls and dispatch recordings for the incident; and the deputies’ histories as law enforcement officers.
No recorded audio or video evidence of the shooting exists. The investigation determined that Wood and Roland had body cameras issued by the Adams County Sheriff’s Office, but that neither body camera recorded the shooting. The investigation determined that Wood’s body camera’s memory was full and that Roland did not activate his body camera.
In order to proceed with a prosecution under the applicable federal criminal civil rights law, Title 18, U.S. Code, Section 242, federal prosecutors must establish beyond a reasonable doubt that a law enforcement officer acted willfully to deprive an individual of a constitutional right. In this investigation, the right involved was Mr. Yantis’s Fourth Amendment right to be free from an unreasonable seizure, which includes the right to be free from unreasonable physical force by law enforcement officers.
To prove that a shooting violated the Fourth Amendment, federal prosecutors must prove beyond a reasonable doubt that the use of force was objectively unreasonable based on all of the surrounding circumstances. The law requires that the reasonableness of an officer’s use of force be judged from the perspective of a reasonable officer on the scene, and not from the added perspective of hindsight. The law set forth by the U.S. Supreme Court requires consideration of the fact that law enforcement officers are often forced to make split-second judgments in circumstances that are tense, uncertain, and rapidly evolving.
In addition, to prove that a shooting violated section 242, federal prosecutors must prove beyond a reasonable doubt that the officers acted willfully. This high legal standard – one of the highest standards of intent imposed by law – requires proof that the officer acted with the specific intent to do something that the law forbids. It is not enough to show that the officer made a mistake, acted negligently, acted by accident, or even exercised bad judgment.
Mr. Yantis’s death is tragic, is a tremendous loss to his family and has had a substantial effect on the Adams County community. However, the evidence does not meet the substantial evidentiary requirements imposed by the criminal law. In light of this, and for the reasons explained below, this matter is not a prosecutable violation of the applicable federal civil rights statute.
Roland and Wood each provided multiple statements to state investigators and/or the FBI offering their versions of how and why this shooting occurred. Some statements were written and some were recorded by investigators. In addition, the deputies each separately participated in a walk-through demonstration with state investigators that was audio and video recorded. Neither the deputies’ statements nor their demonstrations of their actions in the walk-through proved that they acted willfully. Accordingly, federal prosecutors determined that in assessing whether the evidence was sufficient to prove that the deputies acted willfully, they would need to examine whether other evidence corroborated or disproved the deputies’ statements and demonstrations. They also determined that they would need to assess whether other evidence affirmatively proved that the deputies acted willfully.
Only four witnesses observed the shooting: Roland, Wood and two civilian eyewitnesses. All four eyewitnesses to the shooting were consistent on certain facts: that Mr. Yantis possessed a rifle with which he was preparing to shoot or euthanize his injured bull; that Roland and Wood also were nearby; that Mr. Yantis aimed his rifle at the bull’s head to shoot it; that there was some sort of exchange, whether verbal or physical, between one or more of the deputies and Mr. Yantis, during which Mr. Yantis moved or was moved away from the bull; that as Mr. Yantis moved away from the bull, the barrel of his rifle changed directions away from the bull; and that the deputies fired at Mr. Yantis at that point. Although the witnesses did not agree on whether Mr. Yantis’s rifle discharged, investigators determined through forensic evidence that it did. Federal prosecutors concluded that the forensic evidence and all other evidence was insufficient to resolve inconsistencies among the eyewitness statements on other topics, such as in which order the fired shots occurred and what precisely caused the movement of Mr. Yantis’s rifle away from the bull’s head. Based on all of this evidence, federal prosecutors determined that the evidence was insufficient to prove, beyond a reasonable doubt, that either Roland or Wood acted willfully with a bad purpose to violate the law. Accordingly, the Department of Justice’s review of this incident will be closed without prosecution. This decision is limited strictly to an application of the high legal standard required to prosecute the case under the federal criminal civil rights statute; it does not reflect an assessment of any other aspect of the incident that led to Mr. Yantis’s death.
In this case, the U.S. Attorney’s Office for the District of Idaho and the FBI each devoted significant time and resources to investigating the circumstances surrounding Mr. Yantis’s death and, working with the Justice Department’s Civil Rights Division, to complete a thorough analysis of the evidence gathered. The U.S. Attorney’s Office and the FBI received full cooperation from the Idaho State Police, the primary investigative agency on the incident. The U.S. Attorney’s Office, the FBI and the Civil Rights Division, together as the Department of Justice, remain committed to investigating allegations of excessive force by law enforcement officers and will continue to devote the resources required to ensure that all serious allegations of civil rights violations are thoroughly examined.