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US DOJ Indictment Against Kelly Goodlett
US DOJ Indictment Against Kelly Goodlett
INFORMATION
March 2020, had lived for several years at 3003 Springfield Drive, Apartment 4.
2. The Louisville Metro Police Department (LMPD) in late 2019 had formed a unit
called Place-Based Investigations (PBI). In early 2020, PBI was investigating alleged narcotics
trafficking that was centered in the West End area of Louisville, approximately 10 miles away
3. KELLY GOODLETT was a detective in the PBI unit who, as of early 2020, had
4. KYLE MEANY was an LMPD sergeant who supervised the PBI unit. He had been
5. JOSHUA JAYNES was a detective in the PBI unit who, as of early 2020, had
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6. On March 12, 2020, PBI obtained warrants to search five properties. These
included four properties in Louisville’s West End neighborhood that were allegedly used in drug
trafficking, as well as Taylor’s home at 3003 Springfield Drive, Apartment 4 (the Springfield Drive
warrant). The primary target of the investigation was J.G., a man who had been previously arrested
7. On March 13, 2020, at approximately 12:45 a.m., LMPD officers who had not been
involved in drafting the search warrant and who were unaware of the false statements in it executed
the warrant at Taylor’s home. When those officers broke down the door to the apartment, a guest
in Taylor’s home (K.W.), believing that intruders were breaking in, immediately fired one shot
with a handgun that he lawfully possessed, hitting the first officer at the door. Two LMPD officers
instantly fired a total of 22 shots into the apartment, and one of those shots hit Breonna Taylor in
the chest. A third officer moved from the doorway to the side of the apartment and fired ten more
shots through a window and a sliding glass door, both of which were covered with blinds and
curtains.
Paragraphs 1 through 8 are hereby incorporated by reference into the count set forth below.
COUNT ONE
(Conspiracy)
Beginning not later than in or around January 2020, and continuing until in or around June
2022, in the Western District of Kentucky and elsewhere, KELLY GOODLETT knowingly and
willfully conspired and agreed with JOSHUA JAYNES, and others known and unknown to the
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United States, to commit offenses against the United States; specifically (1) to knowingly falsify
a warrant affidavit for Breonna Taylor’s home, in violation of 18 U.S.C. § 242; and (2) to
knowingly engage in misleading conduct toward another person, with the intent to hinder, delay,
and prevent the communication of information to a federal law enforcement officer and judge
relating to the commission and possible commission of a federal offense, in violation of 18 U.S.C
§ 1512(b)(3).
1. One object of the conspiracy was to submit a falsified affidavit in order to obtain a warrant
2. It was part of the manner and means of the conspiracy for KELLY GOODLETT and
JOSHUA JAYNES to put false and misleading information in the Springfield Drive
warrant affidavit.
3. Another object of the conspiracy was to cover up, after the shooting, the fact that the
warrant had been based on information that was false, misleading, stale, and unsupported
by probable cause.
4. It was part of the manner and means of the conspiracy for KELLY GOODLETT and
JOSHUA JAYNES to call, text, and meet with each other to discuss the false information
in the Springfield Drive warrant affidavit and to coordinate their false cover story in an
attempt to escape responsibility for their roles in preparing the warrant affidavit that
5. It was further part of the manner and means of the conspiracy for KELLY GOODLETT
and JOSHUA JAYNES to make false and misleading statements during interviews with
criminal investigators.
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Overt Acts
and her conspirators committed the following overt acts, among others:
draft of the Springfield Drive affidavit in which he claimed that he had “verified” from a
Postal Inspector that J.G. was receiving packages at Taylor’s address. KELLY
GOODLETT knew this claim was false because JOSHUA JAYNES had previously told
her that he had been told that there was no evidence of J.G. receiving packages at
Springfield Drive. Despite knowing that this allegation was false, KELLY GOODLETT
2. On or around March 10 or 11, 2020, KELLY GOODLETT told JOSHUA JAYNES that
the Springfield Drive warrant affidavit did not contain enough recent information
connecting Taylor or her home to criminal activity; she then added a paragraph to the
affidavit that she knew was misleading, which stated that detectives had “verified” from
databases that, as of February 20, 2020, J.G. used 3003 Springfield Drive as his “current
home address.”
3. On or about May 17, 2020––after media outlets reported that a Postal Inspector had
announced that J.G. had not received packages at Taylor’s address as alleged in the
that a criminal investigator wanted to meet with him the following day and arranged to
4. When JOSHUA JAYNES and KELLY GOODLETT met in the garage on the evening of
May 17, 2020, JOSHUA JAYNES relayed to KELLY GOODLETT that they needed to
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get on the same page because they could both go down for putting false information in the
5. During the meeting in the garage, JOSHUA JAYNES and KELLY GOODLETT agreed
to tell investigators a false story, claiming that Sgt. J.M. had told them in January 2020 that
6. On or about May 19, 2020, two days after the garage meeting, JOSHUA JAYNES falsely
claimed to investigators with LMPD’s Public Integrity Unit that, in January 2020, Sgt. J.M.
had told him and KELLY GOODLETT “nonchalantly” that “your guy [J.G.] just gets
7. On or about August 12, 2020, KELLY GOODLETT falsely told investigators with the
Kentucky Office of the Attorney General that, in January 2020, “[J.M.] in passing” had
told KELLY GOODLETT and JOSHUA JAYNES that he “verified [J.G.] was getting
8. On or about June 14, 2022, during an interview with agents with the Federal Bureau of
Investigation, JOSHUA JAYNES falsely claimed that, in January 2020, Sgt. J.M. “made a
nonchalant comment” that J.G. was getting “mail or Amazon packages” at Taylor’s home.
KRISTEN CLARKE
ASSISTANT ATTORNEY GENERAL
CIVIL RIGHTS DIVISION
ZACHARY DEMBO
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PENALTIES
NOTICE
ANY PERSON CONVICTED OF AN OFFENSE AGAINST THE UNITED STATES SHALL BE SUBJECT TO SPECIAL
ASSESSMENTS, FINES, RESTITUTION & COSTS.
SPECIAL ASSESSMENTS
18 U.S.C. § 3013 requires that a special assessment shall be imposed for each count of a conviction of offenses committed after
November 11, 1984, as follows:
FINES
In addition to any of the above assessments, you may also be sentenced to pay a fine. Such fine is due immediately unless the court
issues an order requiring payment by a date certain or sets out an installment schedule. You shall provide the United States Attorney's
Office with a current mailing address for the entire period that any part of the fine remains unpaid, or you may be held in contempt of
court. 18 U.S.C. § 3571, 3572, 3611, 3612
INTEREST will accrue according to the Federal Civil Post-Judgment Interest Rate in effect at
the time of sentencing. This rate changes monthly. Interest accrues from the first business day
following the two week period after the date a fine is imposed.
PENALTIES of:
2. Recordation of a LIEN shall have the same force and effect as a tax lien.
If you WILLFULLY refuse to pay your fine, you shall be subject to an ADDITIONAL FINE
of not more than the greater of $10,000 or twice the unpaid balance of the fine; or
IMPRISONMENT for not more than 1 year or both. 18 U.S.C. § 3615
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RESTITUTION
If you are convicted of an offense under Title 18, U.S.C., or under certain air piracy offenses, you may also be ordered to make
restitution to any victim of the offense, in addition to, or in lieu of any other penalty authorized by law. 18 U.S.C. § 3663
APPEAL
If you appeal your conviction and the sentence to pay your fine is stayed pending appeal, the court shall require:
1. That you deposit the entire fine amount (or the amount due under an installment schedule
during the time of your appeal) in an escrow account with the U.S. District Court Clerk, or
18 U.S.C. § 3572(g)
PAYMENTS
If you are ordered to make payments to the U.S. District Court Clerk's Office, certified checks or money orders should be made payable
to the Clerk, U.S. District Court and delivered to the appropriate division office listed below:
If the court finds that you have the present ability to pay, an order may direct imprisonment until payment is made.
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