Darrell Brooks Jr. Amended Complaint

Case 2021CF001848 Document 42 Filed 01-12-2022 Page 1 of 32
FILED
01-12-2022
Clerk of Circuit Court
Waukesha County
2021CF001848
STATE OF WISCONSIN CIRCUIT COURT WAUKESHA COUNTY
STATE OF WISCONSIN DA Case No.: 2021WK007545

Plaintiff, Assigned DA/ADA: Susan L. Opper
Agency Case No.: 21-047493
vs. Court Case No.: 2021CF001848
Darrell E Brooks ATN: 68006003143373

4014 N 19Th St 68006003143373
Milwaukee, WI 53209
DOB: 02/21/1982 Kevin Costello
Sex/Race: M/B
Eye Color: Brown SECOND
Hair Color: Black AMENDED CRIMINAL COMPLAINT
Height: 5 ft 7 in
Weight: 126 lbs
Alias:
Defendant.
The undersigned, of the Waukesha County District Attorney’s Office, being first duly sworn on
oath, upon information and belief, states that:
Count 1: FIRST DEGREE INTENTIONAL HOMICIDE, USE OF A DANGEROUS WEAPON
The above-named defendant on or about Sunday, November 21, 2021, on Main Street, in the
City of Waukesha, Waukesha County, Wisconsin, did cause the death of VICTIM A, with intent
to kill that person, contrary to sec. 940.01(1)(a), 939.50(3)(a), 939.63(1)(b) Wis. Stats., a Class
A Felony, and upon conviction shall be sentenced to imprisonment for life.
And further, invoking the provisions of sec. 939.63(1)(b) Wis. Stats., because the defendant
committed this offense while using a dangerous weapon, the maximum term of imprisonment
for the felony may be increased by not more than 5 years.
City of Waukesha, Waukesha County, Wisconsin, did cause the death of VICTIM B, with intent
01/12/2022
STATE OF WISCONSIN - VS - Darrell E Brooks
City of Waukesha, Waukesha County, Wisconsin, did cause the death of VICTIM C, with intent
City of Waukesha, Waukesha County, Wisconsin, did cause the death of VICTIM D, with intent
City of Waukesha, Waukesha County, Wisconsin, did cause the death of VICTIM E, with intent
City of Waukesha, Waukesha County, Wisconsin, did cause the death of VICTIM F, with intent
01/12/2022 2
Count 7: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

DANGEROUS WEAPON
City of Waukesha, Waukesha County, Wisconsin, did recklessly endanger the safety of
VICTIM G, under circumstances which show utter disregard for human life, contrary to sec.
941.30(1), 939.50(3)(f), 939.63(1)(b) Wis. Stats., a Class F Felony, and upon conviction may
be fined not more than Twenty Five Thousand Dollars ($25,000), or imprisoned not more than
twelve (12) years and six (6) months, or both.

DANGEROUS WEAPON
VICTIM H, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM I, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM J, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 3

DANGEROUS WEAPON
VICTIM K, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM L, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM M, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 4

DANGEROUS WEAPON
VICTIM N, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM O, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM P, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 5

DANGEROUS WEAPON
VICTIM Q, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM R, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM S, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM T, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 6

DANGEROUS WEAPON
VICTIM U, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM V, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM W, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 7

DANGEROUS WEAPON
VICTIM X, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM Y, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM Z, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 8

DANGEROUS WEAPON
VICTIM AA, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM BB, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM CC, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM DD, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 9

DANGEROUS WEAPON
VICTIM EE, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM FF, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM GG, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 10

DANGEROUS WEAPON
VICTIM HH, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM II, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM JJ, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 11

DANGEROUS WEAPON
VICTIM KK, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM LL, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM MM, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM NN, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 12

DANGEROUS WEAPON
VICTIM OO, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM PP, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM QQ, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 13

DANGEROUS WEAPON
VICTIM RR, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM SS, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM TT, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 14

DANGEROUS WEAPON
VICTIM UU, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM VV, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM WW, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM XX, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 15

DANGEROUS WEAPON
VICTIM YY, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM ZZ, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM AAA, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 16

DANGEROUS WEAPON
VICTIM BBB, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM CCC, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM DDD, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 17

DANGEROUS WEAPON
VICTIM EEE, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM FFF, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM GGG, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM HHH, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 18

DANGEROUS WEAPON
VICTIM III, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM JJJ, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM KKK, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 19

DANGEROUS WEAPON
VICTIM LLL, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM MMM, under circumstances which show utter disregard for human life, contrary to sec.

DANGEROUS WEAPON
VICTIM NNN, under circumstances which show utter disregard for human life, contrary to sec.
01/12/2022 20

DANGEROUS WEAPON
VICTIM OOO, under circumstances which show utter disregard for human life, contrary to sec.
Count 68: HIT AND RUN - RESULTING IN DEATH
City of Waukesha, Waukesha County, Wisconsin, did operate a vehicle involved in an accident
that resulted in death of VICTIM A and failed to reasonably investigate what was struck and if
the operator knew or had reason to know that the accident resulted in injury or death of a
person or in damage to a vehicle that is driven or attended by a person, and failed to stop the
vehicle he was operating as close to the scene of the accident as possible and remain at the
scene of the accident until he did the all of the following: give his name, address and the
registration number of the vehicle he or she was operating to the operator or occupant of or
person attending any vehicle collided with and, upon request and if available, exhibit his
operator's license to the operator or occupant of or person attending any vehicle collided with
and render reasonable assistance to any person injured in the accident, including transporting,
or making arrangements to transport the person to a physician, surgeon, or hospital for
medical or surgical treatment if it is apparent that medical or surgical treatment is necessary or
if requested by the injured person, contrary to sec. 346.67(1) and 346.74(5)(d), 939.50(3)(d)
Wis. Stats., a Class D Felony, and upon conviction may be fined not more than One Hundred
Thousand Dollars ($100,000), or imprisoned not more than twenty five (25) years, or both.
And furthermore, invoking the provisions of Wisconsin Statute 343.31(3)(j), the Department
shall revoke the defendant's operating privilege for five (5) years.
that resulted in death of VICTIM B and failed to reasonably investigate what was struck and if
01/12/2022 21
that resulted in death of VICTIM C and failed to reasonably investigate what was struck and if
that resulted in death of VICTIM D and failed to reasonably investigate what was struck and if
01/12/2022 22

that resulted in death of VICTIM E and failed to reasonably investigate what was struck and if
that resulted in death of VICTIM F and failed to reasonably investigate what was struck and if
01/12/2022 23
Count 74: FELONY BAIL JUMPING
City of Waukesha, Waukesha County, Wisconsin, having been charged with a felony and
having been released from custody under Chapter 969 Wis. Stats., did intentionally fail to
comply with the terms of his bond, contrary to sec. 946.49(1)(b), 939.50(3)(h) Wis. Stats., a
Class H Felony, and upon conviction may be fined not more than Ten Thousand Dollars
($10,000), or imprisoned not more than six (6) years, or both.
Count 75: FELONY BAIL JUMPING
City of Waukesha, Waukesha County, Wisconsin, having been charged with a felony and
having been released from custody under Chapter 969 Wis. Stats., did intentionally fail to
comply with the terms of his bond, contrary to sec. 946.49(1)(b), 939.50(3)(h) Wis. Stats., a
Class H Felony, and upon conviction may be fined not more than Ten Thousand Dollars
($10,000), or imprisoned not more than six (6) years, or both.
Count 76: MISDEMEANOR BATTERY, DOMESTIC ABUSE
The above-named defendant on or about Sunday, November 21, 2021, at Frame Park, in the
City of Waukesha, Waukesha County, Wisconsin, did cause bodily harm to VICTIM PPP, by
an act done with intent to cause bodily harm to that person, without that person's consent,
contrary to sec. 940.19(1), 939.51(3)(a), 968.075(1)(a) 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.
And further, invoking the provisions of sec. 968.075(1)(a) Wis. Stats., because this charge is
an act of domestic abuse, costs upon conviction would include the domestic abuse
assessment imposed under sec. 973.055(1) Wis. Stats.
Count 77: MISDEMEANOR BATTERY, DOMESTIC ABUSE
The above-named defendant on or about Saturday, November 20, 2021, at Frame Park, in the
City of Waukesha, Waukesha County, Wisconsin, did cause bodily harm to VICTIM PPP, by
an act done with intent to cause bodily harm to that person, without that person's consent,
contrary to sec. 940.19(1), 939.51(3)(a), 968.075(1)(a) 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.
01/12/2022 24
And further, invoking the provisions of sec. 968.075(1)(a) Wis. Stats., because this charge is
an act of domestic abuse, costs upon conviction would include the domestic abuse
assessment imposed under sec. 973.055(1) Wis. Stats.
PROBABLE CAUSE:
And prays that the defendant be dealt with according to law; that the basis for the
complainant’s charge of such offense is: Based upon the information from various law
enforcement officers with the City of Waukesha Police Department, believed to be truthful and
reliable in this instance.
On November 21, 2021, Detective Casey was working traffic control for the annual Waukesha
Christmas Parade, which was being held in the downtown area of the City of Waukesha,
Waukesha County, Wisconsin. He was assigned to traffic control at the intersection of White
Rock Avenue and East Main Street. The staging area for the parade participants was on White
Rock Avenue from Perkins Avenue south to East Main Street. There were approximately one
hundred entries in the parade, with hundreds of participants, and thousands of people
watching the parade. The parade had already started and there were numerous people,
vehicles, and floats already on the parade route on East Main Street.
At approximately 4:35 p.m., Detective Casey heard via the Waukesha police radio that a
reserve officer was informed by a citizen that two people were fighting in the area of White
Rock School. Squads were sent to that area to further investigate. A few minutes later,
Detective Casey heard a horn honking from an area north of his location. Detective Casey
went out onto White Rock Avenue to see where the horn sound was coming from. He
observed that White Rock Avenue was filled with parade participants, as was East Main Street.
He began to see people spreading apart and observed a red Ford Escape driving southbound
on White Rock Avenue. He observed people jumping out of the way of the red Ford Escape.
As the Ford Escape was at White Rock Avenue and East Main Street, Detective Casey
stepped in front of the Ford Escape and pounded on the hood of the vehicle and yelled
multiple times, “Stop.” Detective Casey was wearing a shirt with patches on both shoulders
that stated, “Waukesha Police”, as well as wearing a black hat with white letters on the front of
the hat which stated “Police”. Further, he was wearing a neon orange safety vest that stated
“Police” on the front and back of it.
The Ford Escape continued driving and turned westbound on East Main Street. At that time,
the vehicle was driving at a slow speed and the vehicle brushed Detective Casey back off of
the front of the car, causing him to be positioned down the driver’s side of the vehicle.
Detective Casey went to the driver’s side window and pounded on the driver’s side door
yelling, “Stop”. Detective Casey subsequently positively identified the driver of the Ford Escape
as Darrell E. Brooks, Jr., DOB: 2/21/82, hereinafter referred to as the defendant. The
defendant drove past Detective Casey and into the parade procession. Detective Casey
chased the vehicle to East Avenue on foot and he observed the vehicle begin to drive faster.
Detective Casey broadcast over the radio that the red Ford Escape had entered the parade
route and he needed squads to respond in an emergency fashion. A few seconds later,
Detective Casey heard on the police radio that the vehicle was striking people and was
continuing westbound on East Main Street.
01/12/2022 25
While the defendant was driving westbound on Main Street, he struck numerous pedestrians,
which included both parade participants and spectators located on the side of the street.
Detective Casey later observed three adult victims in the road in the 300 block of W. Main
Street. These victims were subsequently identified as VICTIM A, VICTIM B AND VICTIM C. All
three of these victims had traumatic injuries as a result of being hit by the vehicle the
defendant was driving and all three were subsequently pronounced dead. VICTIM D, an adult,
was transported to Waukesha Memorial Hospital and she subsequently died as a result of the
injuries she sustained as a result of being struck by the defendant’s vehicle. VICTIM E, an
adult, was transported to Aurora Summit and he subsequently died as a result of the injuries
he sustained as a result of being struck by the defendant’s vehicle. Dr. Lynda Biedrzycki and
Dr. Amy Sheil of the Waukesha County Medical Examiner’s office have completed external
examinations on all of the deceased victims. They have concluded the Cause of Death for
Victim A, Victim B, Victim C, Victim D and Victim E was multiple blunt force injuries.
Detective Casey further reports that on November 23, 2021, he was advised that another
parade participant, Victim F, a child, had died in the hospital. Detective Casey reported Victim
F had suffered significant injuries as a result of being hit by the vehicle the defendant was
driving. Dr. Amy Sheil of the Waukesha County Medical Examiner’s office performed an
autopsy on Victim F and concluded the Cause of Death was Craniocerebral Injures from Blunt
Force Trauma to the Head.
Officer Butryn was assisting with crowd control in the area of East Main Street and North East
Avenue. At approximately 4:38 p.m., Officer Butryn heard on his radio that a car was traveling
westbound, approaching the parade route. Officer Butryn observed a red Ford Escape
traveling westbound on White Rock Avenue, approaching East Main Street. He began walking
onto East Main Street, into the parade, in an attempt to get the driver’s attention, stop the
vehicle and redirect the vehicle from the parade route. The vehicle turned right onto East Main
Street, toward Officer Butryn. As the vehicle was traveling westbound on East Main Street,
Officer Butryn was standing directly in-line with the vehicle, wearing a full City of Waukesha
Police Department uniform. He put his hand up and yelled, “Stop, stop the vehicle” multiple
times.
Based upon his training and experience, Officer Butryn estimated the vehicle's speed to be
approximately 25 miles per hour. The vehicle was initially sticking to the north side of the road,
in the open lane between the parade participants and spectators. Officer Butryn observed the
driver looking straight ahead, directly at him, and it appeared he had no emotion on his face.
As the vehicle passed his location, Officer Butryn continually yelled for the vehicle to stop. The
vehicle continued traveling westbound on East Main Street, and passed through the
intersection of East Main Street and Buckley Street. Office Butryn concluded that if the driver
was lost and attempting to get out of the parade, this would have been a reasonable location
for him to stop and exit the parade route. The vehicle continued westbound on East Main
Street and was honking its horn. As the vehicle got to approximately Martin Street, it appeared
to Officer Butryn that the vehicle began to increase its speed. As the vehicle was traveling
westbound, the vehicle began getting closer to parade spectators, and almost struck a small
juvenile who was standing in one of the parking stalls on the north side of the road as its speed
was increasing.
01/12/2022 26
The vehicle then got to the intersection of East Main Street and NW Barstow Street, and it
appeared the brakes were activated. Office Butryn believed the vehicle was going to come to a
stop and attempt to make a right hand turn out of the parade route, onto NW Barstow Street.
However, the vehicle then appeared to rapidly accelerate, as Officer Butryn heard tires squeal.
The vehicle took an abrupt left turn into the crowd of parade participants. At this point, it was
clear to Officer Butryn that this was an intentional act to strike and hurt as many people as
possible. Officer Butryn continued to run westbound on East Main Street, trailing the vehicle
and its path. He observed the vehicle appeared to be intentionally moving side to side, striking
multiple people, and bodies and objects were flying from the area of the vehicle. As Officer
Butryn got to the area of the Subway restaurant on East Main Street, Officer Butryn began to
encounter multiple casualties. Multiple people were pulling at him, saying that they needed
assistance with injured parties. Based on the on-going threat of the vehicle and the occupant,
Officer Butryn asked those assisting with the casualties as he passed, if they were breathing,
and advised them to stay with them and that ambulances were on the way. Officer Butryn
continued to chase after the vehicle on foot in order to stop the threat the driver posed.
Detective Casey spoke with Officer Scholten, who indicated he saw the Ford Escape traveling
southbound on West Main Street, approaching Wisconsin Avenue, running over people.
Officer Scholten shot at the vehicle three times, striking it three times.
Detective Trussoni spoke with multiple citizen witnesses who were present during the parade.
One witness indicated, “As I continued to watch the SUV, it continued to drive in a zig zag
motion. It was like the SUV was trying to avoid vehicles, not people. There was no attempt
made by the vehicle to stop, much less slow down.”
Detective Trussoni spoke with another witness who described the same zig zag driving pattern
by the SUV and the witness further indicated, he felt it was “a direct intent to hit as many
parade participants.”
In addition to the deaths, Detective Casey reports several dozen people were endangered and
injured by the conduct of Brooks.
Detective Casey reports that VICTIM G was participating in the parade as part of the RE/MAX
Services First Group. VICTIM G was struck directly by the SUV in the street near the area of
Smart Asset Realty located at 200 W. Main St. VICTIM G suffered substantial bodily harm per
§939. 22(38), Wis. Stats., as a result of being struck.
Detective Casey reports that VICTIMS H-Q were participating in the parade as part of the
Waukesha South Band. VICTIMS H-K and M-Q were struck directly by the SUV in the street
near the area of Divino Gelato/ Subway located at 215 and 227 W. Main St. VICTIMS H-K and
M-Q were all injured as a result of being struck by the SUV. The injuries ranged in severity
from bodily harm per §939. 22(4), Wis. Stats., to great bodily harm per §939. 22(14), Wis.
Stats . VICTIM L was walking in the street as the SUV approached the group. VICTIM L
reported that he was not sure if he was hit or knocked down by someone else that was hit
which then caused him to be knocked down, but it did occur as the SUV drove into his group.
VICTIM L suffered bodily harm.
01/12/2022 27
Detective Casey reports that VICTIMS R and S were participating in the parade as part of the
Burris Logistics group. VICTIMS R and S were struck directly by the SUV near the area of the
antique store located at 259 W. Main St. VICTIMS R and S were both injured as a result of
being struck by the SUV. The injuries ranged in severity from bodily harm to substantial bodily
harm.
Detective Casey reports that VICTIMS T, U, V and W were participating in the parade as part
of the Waukesha Blazers Baseball team. VICTIMS T, U, V and W were directly struck by the
SUV near the area of the Waukesha Civic Theater located at 264 W. Main St. VICTIMS T, U,
V and W were all injured as a result of being struck by the SUV. The injuries ranged in
severity from bodily harm to great bodily harm.
Detective Casey reports that VICTIMS X-LL were participating in the parade as part of the
Waukesha Xtreme Dance team. VICTIM X, AA and CC were walking in the street near the
area of W. Broadway and W. Main Street as the SUV approached the group. VICTIM X, AA
and CC reported that they were not sure if they were hit by the SUV or struck by someone else
that was hit, but it did occur as the SUV drove into their group and they all suffered injuries.
VICTIMS Y, Z, BB and DD-LL were struck directly by the SUV in the street near the area of W.
Broadway and W. Main St. VICTIMS Y, Z, BB and DD-LL were all injured as a result of being
struck by the SUV. The injuries ranged in severity from bodily harm to great bodily harm.
Detective Casey reports that VICTIMS MM, NN and OO were participating in the parade as
part of the Milwaukee Dancing Grannies. VICTIMS MM, NN and OO were struck directly by
the SUV in the street in the 300 block of W. Main St. VICTIMS MM, NN and OO were all
injured as a result of being struck by the SUV. The injuries ranged in severity from bodily harm
to great bodily harm.
Detective Casey reports that VICTIMS PP-HHH were participating in the parade as part of the
Catholic Community of Waukesha. VICTIM PP was walking in the street near the area of 426
W. Main St. as the SUV approached the group. VICTIM PP reported that she hurt her leg but
was unsure if it was due to being struck by the SUV or another person, but it did occur as the
SUV drove into her group. VICTIM TT also reported he was walking in the street and he
believed the people next to him were hit and that person was pushed into VICTIM TT, causing
injury to him. VICTIMS QQ-SS and UU-HHH were all struck directly by the SUV and were all
injured as a result of being struck by the SUV. The injuries ranged in severity from bodily harm
to great bodily harm.
Detective Casey reports that VICTIMS III and JJJ were spectators who were present to
observe the parade. VICTIMS III and JJJ were on the side of the road and struck by the SUV
near the area of W. Broadway and W. Main St. VICTIMS III and JJJ were both injured as a
result of being struck by the SUV. The injuries resulted in substantial bodily harm to both.
Detective Casey reports that VICTIMS KKK and LLL were spectators who were present to
observe the parade. VICTIMS KKK and LLL were on the side of the road and struck by the
SUV near the area of 231 W. Main St. VICTIMS KKK and LLL were both injured as a result of
being struck by the SUV. The injuries ranged in severity from bodily harm to substantial bodily
harm.
01/12/2022 28
Detective Casey reports that VICTIMS MMM, NNN and OOO were spectators who were
present to observe the parade. VICTIMS MMM, NNN and OOO were on the side of the road
and struck by the SUV near the area of 340 W. Main St. VICTIMS MMM, NNN and OOO were
all injured as a result of being struck by the SUV. The injuries ranged in severity from
substantial bodily harm to great bodily harm.
Detective Casey further reports the distance Brooks drove from the point of first striking
VICTIM G near the start of the parade route until he struck multiple persons walking with the
Catholic Community of Waukesha was over 1/3 of a mile. Brooks struck parade participants
from at least 8 different groups marching in the parade, spread out over the course of about 5
blocks, and some spectators along the way. All of the victims who were killed and most of the
people that were injured were walking right down the middle of the road in plain view. Main
Street was clearly closed to through traffic, there were barricades in place and police present
to direct motorists for the entire length of the parade route.
Detective Casey has viewed multiple video recordings of the incident recovered from various
businesses and citizen cell phone recordings. At no time does the vehicle stop to avoid
striking any person. Detective Casey observed Brooks’ vehicle intentionally striking multiple
people from each of the groups in direct, head-on fashion. Detective Casey observed that at
times, the vehicle traveled from the north side of the road to the south side of the road, striking
several parade participants in the middle of the road along the way. Detective Casey further
observed in the video recordings that Brooks increased the speed of the vehicle at times and
rarely applied its brakes. Detective Casey further reports that some of the video recordings
depict Brooks driving the SUV over persons who have been knocked down and on at least one
occasion where the position of the vehicle changes horizontally as the SUV goes up and over
persons laying in the road after being knocked over by Brooks’ SUV. After this, Brooks does
not stop but continues down the road, striking and killing several people. Detective Casey
further reports that the video recordings also depict multiple people and objects being carried
for a distance on the hood/windshield of the vehicle at various times after being struck by
Brooks’ SUV. At one point, Brooks leaned his head out the window to steer because there
was a person on the windshield blocking his vision, however, Brooks does not stop but
continues driving.
Detective Casey further reports that a complete mechanical inspection of the vehicle was
performed by Mechanical Inspector Ryan Schultz with the Wisconsin State Patrol and all
necessary functions such as steering, braking and accelerating were found to be fully
operational.
Detective Behrendt reports that it was learned that Brooks had several open cases regarding
domestic abuse incidents involving his ex-girlfriend, VICTIM PPP. Brooks had been charged
in Milwaukee County case no. 2020CF002550 with two counts of Second Degree Recklessly
Endangering Safety, Use of a Dangerous Weapon, contrary to Sections 941.30 (2) and 939.63
(1)(b), Wisconsin Statutes, and a third count of Possess Firearm-Convicted of a Felony,
contrary to Section 941.29 (1m)(a), Wisconsin Statutes. Brooks made an initial court
appearance in that case on July 28, 2020, and cash bond was set in the amount of $10,000
with the condition that he not commit any further crimes. The bail was amended to $7,500
cash with the same conditions on August 13, 2020. The bail was again modified down to $500
01/12/2022 29
cash bail on February 9, 2021, with all previous conditions of bail remaining. Cash bail was
posted and he was released on bail. This bail was in full effect on November 21, 2021.
Brooks was also charged in Milwaukee County case no. 2021CF004596 with one count of
Resisting/Obstructing, contrary to Section 946.41, Wisconsin Statutes, Felony Bail Jumping,
contrary to Section 946.49 (1)(b), Wisconsin Statutes, one count Second Degree Recklessly
Endangering Safety-Domestic Abuse, contrary to Section 941.30 (2), and Section 973.055 (1),
one count of Disorderly Conduct-Domestic Abuse, contrary to , contrary to Section 947.01 (1)
and Section 973.055 (1), and one count of Battery - Domestic Abuse , contrary to Section
940.19 (1) and Section 973.055 (1). Brooks made an initial appearance on this case on
November 5, 2021, and cash bail was set in the amount of $1,000 with the condition that he
not commit any further crimes and that he have no contact with VICTIM PPP. Cash bail was
posted and he was released on bail. This bail was in full effect on November 21, 2021.
Detective Behrendt further reports that on November 21, 2021, she did interview VICTIM PPP.
Detective Behrendt noticed that VICTIM PPP had her left eye extremely swollen and bruised
and her right leg was in a boot. VICTIM PPP stated that she received the eye injury on
November 20, 2021, from Brooks. She further reported that she had sustained a broken leg in
a previous incident involving Brooks where he ran her over in a gas station parking lot.
VICTIM PPP stated that Brooks drives a red Ford Escape, which belongs to his mother.
VICTIM PPP reported that Brooks sleeps and lives in the vehicle.
VICTIM PPP reported that on November 20, 2021, she was in Frame Park in the City of
Waukesha, Waukesha County, Wisconsin. VICTIM PPP reported that Brooks had called her
and told her that he could see her and that she ultimately had contact with him that day at the
park. VICTIM PPP reported that she and Brooks got into an argument and he hit her across
her face with his right hand, causing the injury to her eye. VICTIM PPP stated that she is
afraid of Brooks and that he has caused substantial injury to her in the past and has run her
over with his vehicle.
VICTIM PPP further reported that on November 21, 2021, she also saw Brooks vehicle while
she was hanging out at Frame Park. Brooks called her from a private number and she
answered. VICTIM PPP reported that she met up with Brooks and he was alone in his car.
VICTIM PPP stated that nothing physical happened. VICTIM PPP stated that she saw his car
near Frame Park and that she walked up and got into the car and they started arguing.
VICTIM PPP stated that they constantly argue over the fact that she did not bail him out of jail.
VICTIM PPP stated that during the argument he threatened her to “make this end”, but she
wasn’t sure exactly what he meant by that. VICTIM PPP reports that the last thing Brooks said
to her was “Fuck you, bitch, erase my number”, or something to that effect. VICTIM PPP
stated that it was evident that the argument was not going anywhere and she was afraid she
was going to be hurt again so she left the car and saw him drive off, driving past Frame Park at
a high rate of speed.
Detective Guth reports that on November 22, 2021, he spoke with VICTIM PPP again. VICTIM
PPP reported that she was not entirely truthful with Detective Behrendt on November 21, 2021,
because she is fearful of Brooks. VICTIM PPP agreed to cooperate with Detective Guth and
show him the area of Frame Park where she had contact with Brooks on November 21, 2021,
around 4 p.m. VICTIM PPP stated that she was near the baseball diamond in the
01/12/2022 30
southeastern portion of the park and was looking at videos on her phone when she observed
Brooks in the red Ford Escape parked nearby. VICTIM PPP reports that she did approach him
and got into the vehicle. VICTIM PPP stated that Brooks was very upset and angry with her
and accused her of talking to other guys on her phone and at one point attempted to take her
phone from her. She also stated that he began driving around and while he was driving, she
became fearful of his driving because he was driving fast and was only driving with one hand
and was striking her in the face with his other hand. VICTIM PPP stated that as she was
struck, this caused her pain and that he hit her and split her lip and caused her left eye to
become swollen and puffy. They continued to argue as they drove down Baxter Street
towards Buckley Street. When they approached the intersection of Corrina Boulevard and
North Barstow, they drove up the Barstow hill. VICTIM PPP reported that Brooks continued to
yell at her, call her names and tried to take her phone. They stopped at the intersection of
Bidwell and NW Barstow and she got out of the SUV for her own safety. She stated that
Brooks sped off in an unknown direction. She started walking southbound on NW Barstow
back towards the Fox River. She was confronted again by Brooks in his motor vehicle and he
was yelling out his window at her. She described this location as the gas station on the corner
of North Street and NW Barstow. She continued to try and walk and call her friends for help.
VICTIM PPP reported that Brooks was the only person in the SUV at this time. VICTIM PPP
stated that she made her way back to Frame Park and that Brooks again confronted her in
front of White Rock School.
Detective Guth reports that officers were able to obtain video footage of the red SUV and a
partial video recording of a confrontation occurring in front of White Rock School at 4:31 p.m.
on November 21, 2021. Victim PPP was with two friends. On the video recording, Detective
Guth observed that one friend attempted to calm the situation but Brooks pushed the other
friend in the face and then got into his SUV and began to drive off in a southwesterly direction
towards Main Street. VICTIM PPP stated that was the last time she saw Brooks and his SUV.
Detective Casey further reports that the investigation revealed after Brooks left the parade
route after having been fired upon by Officer Scholten, he drove to the area of 338 Maple
Avenue in the red SUV and drove through a backyard, causing additional damage to the SUV.
Brooks abandoned the vehicle at that point and is seen on various video recordings from
businesses and homeowners walking through the neighborhood on foot. Brooks’ appearance
is changed and he is no longer wearing the light colored hoodie sweatshirt that he was wearing
while driving the SUV on Main Street. That item was later found abandoned in a backyard.
Detective Casey reports that the investigation revealed Brooks walked around the
neighborhood for a short period of time, and eventually made contact with the homeowner of
the residence at 553 Elizabeth Street. The police were out looking for the driver of the SUV
and located Brooks at this location and took him into custody at 5:14 pm.
Detective Casey reports that at no time did Brooks, as the operator of the SUV involved in the
multiple collisions, make any reasonable effort to investigate what was struck, and that he
failed to stop the vehicle as close to the scene of the accident as possible, and did not remain
at the scene of the accident.
Based on the foregoing, the complainant believes this complaint to be true and correct.
SLO:jam
01/12/2022 31

Subscribed and sworn to before me on 01/12/22 Electronically Signed By:
Electronically Signed By: Susan L. Opper
Abbey L Nickolie Complainant
Assistant District Attorney
State Bar #: 1092722
01/12/2022 32

Darrell Brooks Jr. Amended Complaint

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Case 2021CF001848 Document 42 Filed 01-12-2022 Page 1 of 32

STATE OF WISCONSIN DA Case No.: 2021WK007545

Darrell E Brooks ATN: 68006003143373

Count 1: FIRST DEGREE INTENTIONAL HOMICIDE, USE OF A DANGEROUS WEAPON

Count 2: FIRST DEGREE INTENTIONAL HOMICIDE, USE OF A DANGEROUS WEAPON

STATE OF WISCONSIN - VS - Darrell E Brooks

Count 3: FIRST DEGREE INTENTIONAL HOMICIDE, USE OF A DANGEROUS WEAPON

Count 4: FIRST DEGREE INTENTIONAL HOMICIDE, USE OF A DANGEROUS WEAPON

Count 5: FIRST DEGREE INTENTIONAL HOMICIDE, USE OF A DANGEROUS WEAPON

Count 6: FIRST DEGREE INTENTIONAL HOMICIDE, USE OF A DANGEROUS WEAPON

STATE OF WISCONSIN - VS - Darrell E Brooks

Count 7: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 8: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 9: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 10: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

STATE OF WISCONSIN - VS - Darrell E Brooks

Count 11: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 12: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 13: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

STATE OF WISCONSIN - VS - Darrell E Brooks

Count 14: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 15: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 16: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

STATE OF WISCONSIN - VS - Darrell E Brooks

Count 17: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 18: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 19: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 20: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

STATE OF WISCONSIN - VS - Darrell E Brooks

Count 21: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 22: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 23: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

STATE OF WISCONSIN - VS - Darrell E Brooks

Count 24: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 25: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 26: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

STATE OF WISCONSIN - VS - Darrell E Brooks

Count 27: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 28: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 29: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 30: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

STATE OF WISCONSIN - VS - Darrell E Brooks

Count 31: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 32: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 33: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

STATE OF WISCONSIN - VS - Darrell E Brooks

Count 34: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 35: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 36: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

STATE OF WISCONSIN - VS - Darrell E Brooks

Count 37: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 38: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 39: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 40: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

STATE OF WISCONSIN - VS - Darrell E Brooks

Count 41: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 42: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 43: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

STATE OF WISCONSIN - VS - Darrell E Brooks

Count 44: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 45: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

Count 46: FIRST DEGREE RECKLESSLY ENDANGERING SAFETY, USE OF A

STATE OF WISCONSIN - VS - Darrell E Brooks