State of Minnesota
County of Hennepin
District Court
4th Judicial District
Prosecutor File No.
Court File No.
State of Minnesota,
16A14657
27-CR-16-32253
COMPLAINT
Plaintiff,
Order of Detention
vs.
RUSSELL JEMIEL CAGE DOB: 04/29/1977
1801 UPTON AVE NORTH
MINNEAPOLIS, MN 55411
Defendant.
The Complainant submits this complaint to the Court and states that there is probable cause to believe
Defendant committed the following offense(s):
COUNT I
Charge: Murder - 3rd Degree - Sell/Give/Distribute Controlled Substance - Schedules 1 & 2
Minnesota Statute: 609.195(b), with reference to: 609.195(b)
Maximum Sentence: 25 YEARS AND/OR $40,000
Offense Level: Felony
Offense Date (on or about): 12/16/2016
Control #(ICR#): 16007438
Charge Description: That on or about 6/30/2016, in Hennepin County, Minnesota, RUSSELL JEMIEL
CAGE, did, without intent to cause death, proximately cause the death of E.B., a human being, by directly
or indirectly, unlawfully selling, giving away, bartering, delivering, exchanging, distributing, or
administering a controlled substance classified in Schedule I or II.
COUNT II
Charge: Drugs - 3rd Degree - Sale - Narcotic
Minnesota Statute: 152.023.1(1), with reference to: 609.101.3, 152.023.3(a)
Maximum Sentence: 20 YEARS AND/OR $75,000-$250,000
Offense Level: Felony
Offense Date (on or about): 12/16/2016
Control #(ICR#): 16007438
Charge Description: That on or about 12/14/2016, in Hennepin County, Minnesota, RUSSELL JEMIEL
CAGE, unlawfully sold, gave away, bartered, delivered, exchanged, distributed, disposed of to another,
offered to sell, agreed to sell, manufactured or possessed with intent to sell one or more mixtures
containing a narcotic drug, to wit: heroin.
COUNT III
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Charge: Drugs - 3rd Degree - Sale - Narcotic
Minnesota Statute: 152.023.1(1), with reference to: 609.101.3, 152.023.3(a)
Maximum Sentence: 20 YEARS AND/OR $75,000-$250,000
Offense Level: Felony
Offense Date (on or about): 12/16/2016
Control #(ICR#): 16007438
Charge Description: That on or about 12/14/2016, in Hennepin County, Minnesota, RUSSELL JEMIEL
CAGE, unlawfully sold, gave away, bartered, delivered, exchanged, distributed, disposed of to another,
offered to sell, agreed to sell, manufactured or possessed with intent to sell one or more mixtures
containing a narcotic drug, to wit: crack cocaine.
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STATEMENT OF PROBABLE CAUSE
Complainant has investigated the facts and circumstances of this offense and believes the following
establishes probable cause:
On June 30, 2016, E.B., a known adult female, was brought to Abbott Northwestern Hospital, City of
Minneapolis, County of Hennepin, State of Minnesota, by her acquaintance, H.A., a known adult female.
E.B. was not responsive and remained so until her death on July 4, 2016, at 0900 hours, at Abbott. The
Hennepin County Medical Examiner’s Office determined that E.B.’s death was as a result of multiple organ
failure caused by heroin toxicity, or overdose. Officers later learned from H.A. that she and E.B. had met with a male, later identified as RUSSELL
JEMIEL CAGE, “the Defendant” herein, to purchase heroin, a schedule I controlled substance, on the day
of E.B.’s death. H.A. reported to officers that the Defendant met E.B. and her behind a McDonald’s in order
to sell E.B. heroin. H.A. told officers that E.B. procured the heroin from the Defendant. H.A. stated that as
she was driving E.B. home from the McDonald’s E.B. reported that she was not feeling well. H.A. stated
that she did not use the heroin, so she was unable to report to officers about its effectiveness. H.A.
reported that E.B. began to vomit before E.B. became unresponsive. Your Complainant is aware that this is
consistent with an overdose. H.A. drove E.B. straight to Abbott where she was able to summon assistance
for E.B. E.B. later died as a result of a heroin overdose. On December 14, 2016, Officers arranged to meet the Defendant through a confidential informant. The CI
was provided with pre-recorded buy money in order to purchase heroin from the Defendant. The Defendant
came to the predetermined meet location in a parking lot at 1200 Shingle Creek Crossing, City of Brooklyn
Center, County of Hennepin, State of Minnesota. Officers monitored the meeting between the CI and the
Defendant. Following the meeting, the CI reported that the exchange had occurred and the Defendant was
detained. The CI provided officers with 0.42 grams of heroin that s/he had purchased from the Defendant.
The heroin field tested positive. In a search of the Defendant’s person, officers recovered the prerecorded buy money as well as nine (9)
baggies of controlled substances packaged for sale. Those nine baggies included:
-0.21 grams of crack cocaine
-0.28 grams of crack cocaine
-0.22 grams of crack cocaine
-0.28 grams of crack cocaine
-0.34 grams of heroin
-0.25 grams of heroin
-0.08 grams of heroin
-0.13 grams of heroin
-0.10 grams of heroin
The crack cocaine field tested positive and weighed 0.99 grams in total. The heroin field tested positive
and weighed 0.9 grams in total.
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SIGNATURES AND APPROVALS
Complainant requests that Defendant, subject to bail or conditions of release, be:
(1) arrested or that other lawful steps be taken to obtain Defendant's appearance in court; or
(2) detained, if already in custody, pending further proceedings; and that said Defendant otherwise
be dealt with according to law.
Complainant declares under penalty of perjury that everything stated in this document is true and
correct. Minn. Stat. § 358.116; Minn. R. Crim. P. 2.01, subds. 1, 2.
Complainant
Jon E Parker
Sergeant
3015 Raleigh Ave S
St Louis Park, MN 55416
Badge: P045
Electronically Signed:
12/16/2016 01:57 PM
Hennepin County, Minnesota
Being authorized to prosecute the offenses charged, I approve this complaint.
Prosecuting Attorney Mike Radmer
300 S 6th St
Minneapolis, MN 55487
(612) 348-5550
Electronically Signed:
12/16/2016 01:36 PM
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FINDING OF PROBABLE CAUSE
From the above sworn facts, and any supporting affidavits or supplemental sworn testimony, I, the Issuing Officer, have
determined that probable cause exists to support, subject to bail or conditions of release where applicable, Defendant’s arrest
or other lawful steps be taken to obtain Defendant’s appearance in court, or Defendant’s detention, if already in custody,
pending further proceedings. Defendant is therefore charged with the above-stated offense(s).
SUMMONS
THEREFORE YOU, THE DEFENDANT, ARE SUMMONED to appear on ________ ___, _____ at _____ AM/PM
before the above-named court at 300 S Sixth Street, Minneapolis, MN 55487 to answer this complaint.
IF YOU FAIL TO APPEAR in response to this SUMMONS, a WARRANT FOR YOUR ARREST shall be issued.
WARRANT
To the Sheriff of the above-named county; or other person authorized to execute this warrant: I order, in the name of the State
of Minnesota, that the Defendant be apprehended and arrested without delay and brought promptly before the court (if in
session), and if not, before a Judge or Judicial Officer of such court without unnecessary delay, and in any event not later than
36 hours after the arrest or as soon as such Judge or Judicial Officer is available to be dealt with according to law.
Execute in MN Only
Execute Nationwide
Execute in Border States
X ORDER OF DETENTION
Since the Defendant is already in custody, I order, subject to bail or conditions of release, that the Defendant continue to be
detained pending further proceedings.
Bail: $500,000.00
Conditions of Release: This complaint, duly subscribed and sworn to or signed under penalty of perjury, is issued by the undersigned Judicial Officer
as of the following date: December 16, 2016.
Judicial Officer
Juan Hoyos
District Court Judge
Electronically Signed: 12/16/2016 02:07 PM
Sworn testimony has been given before the Judicial Officer by the following witnesses:
COUNTY OF HENNEPIN
STATE OF MINNESOTA
State of Minnesota
LAW ENFORCEMENT OFFICER RETURN OF SERVICE
Plaintiff
I hereby Certify and Return that I have served a copy of this Order of
Detention upon the Defendant herein named.
vs.
Signature of Authorized Service Agent:
RUSSELL JEMIEL CAGE
Defendant
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