Case 2023CM000154 Document 2 Filed 02-08-2023 Page 1 of 8

FILED
02-08-2023
Clerk of Circuit Court
Brown County, WI
STATE OF WISCONSIN CIRCUIT COURT BROWN COUNTY
2023CM000154
DA Case No.: 2023BR001033 Honorable Donald R.
Zuidmulder
STATE OF WISCONSIN Assigned ADA: Meranda J Hillmann
Plaintiff, Agency Case No.: 23-700621 Branch 1

vs. Court Case No.: 2023CM

JOEL XAIVER ROBINSON- ATN:

SELLERS
4016 South Federal Street
Chicago, IL 60609 CRIMINAL COMPLAINT
DOB: 06/15/2004
Sex/Race: M/B
Eye Color: Brown
Hair Color: Black
Height: 5 ft 5 in
Weight: 150 lbs
Alias:
Defendant. For Official Use

Complainant, an Assistant District Attorney, being first duly sworn on oath, deposes and says
that:

Count 1: CARRYING A CONCEALED WEAPON

The above-named defendant on or about Tuesday, February 7, 2023, in the City of Green Bay,
Brown County, Wisconsin, not being a peace officer or other person defined in s. 941.23(2),
did go armed with a concealed and dangerous weapon, a firearm, contrary to sec. 941.23(2)
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.

Count 2: POSSESSION OF TETRAHYDROCANNABINOLS (THC)

The above-named defendant on or about Tuesday, February 7, 2023, in the City of Green Bay,
Brown County, Wisconsin, did knowingly possess a controlled substance,
Tetrahydrocannabinols (THC), contrary to sec. 961.41(3g)(e) Wis. Stats., a Misdemeanor, and
upon conviction may be fined not more than One Thousand Dollars ($1,000), or imprisoned for
not more than six (6) months, or both.

And the Court may suspend the defendant's operating privileges for not less than six (6)
months nor more than five (5) years. If the defendant's driving privileges are already
suspended, any suspension imposed must be served consecutively.

Complainant is an Assistant District Attorney with the Brown County District Attorney’s Office
and knows of the above offense(s) on information and belief based upon:

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STATE OF WISCONSIN - VS - Joel Xaiver Robinson-Sellers

PROBABLE CAUSE:

The complainant, being duly sworn on oath, swears that she has had the opportunity to review
the police reports from the University of Wisconsin-Green Bay Police Department, and other
documents supporting this complaint referenced herein, which are the types of reports and
documents kept in the ordinary course of business, which complainant believes to be truthful
and reliable because they have proven to be truthful and reliable on numerous occasions in
the past.

The complainant further asserts that based upon her review of the referenced reports and/or
supporting documents, the incidents alleged occurred in the City of Green Bay, Brown County,
Wisconsin.

1. Your Complainant’s review of the reports of Sgt. Duchateau of the University of Wisconsin-
Green Bay Police Department, who indicates:

Initial Call
On February 7, 2023 at approximately 8:15pm Officer Hendzel and Onyx were notified by
UWGB dispatch of a welfare check at 3362 Schaefer Court. The complainant stated she was
concerned about a male who had been knocking on her door and slurring her words. I
responded to the call as well. See their reports for more information.

Arrival
Upon arrival, Officer Onyx and I went to the 2nd and 3rd floors and did not find a male in the
hallway. At this time, Officer Hendzel notified us that he had located the male in the stairwell of
the 1st floor. We proceeded to that location. Upon arrival to the stairwell, I observed a male,
later identified as Joel ROBINSON-SELLERS, sitting on the stairs talking with Officer Hendzel.
He appeared to be under the influence of something as he was slurring his words and not
making much sense with his responses. I also observed what appeared to be a small
measurable amount of green leafy substance laying on the stairs next to him along with
several lighters and other miscellaneous items. Based on my training and experience I
believed this substance to be marijuana.

At this time, I made contact with Residence Life staff Assistant Director (AD) Lyndsey who was
coming down the stairs. I asked if she was here for the same reason we were and she
indicated that she had also gotten a call about the male being in the building. She was able to
confirm that the male did not live in that building and eventually determined he lived at 3366
Schaefer Court room 302. ROBINSON-SELLERS said he was here because it was where
"Hussein" lived. I am aware of a person with that name who lives at 3356 Leon Bond Dr room
202 due to the fact that we have been called to that area numerous times for the odor of
marijuana. When Officer Hendzel asked him if he had consumed any drugs or alcohol,
ROBINSON-SELLERS stated, "I was gonna to bring that to Hussein" indicating what drugs
were in his backpack.

Evidence Collection
I returned to the patrol vehicles outside to get a bag for the loose leafy substance. I gathered
as much of the substance that I could and placed in into a brown paper bag. The bag was
placed with the rest of the belongings collected by Officer Hendzel and Onyx. ROBINSON-
SELLERS asked if he could have the money out of the bag. I informed him that we would be

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STATE OF WISCONSIN - VS - Joel Xaiver Robinson-Sellers

keeping the cash as evidence due to it being found with drugs and him saying he was
"bringing" the drugs to "Hussein". He then denied saying that and said "I got my own money,
fuck Hussein". Officer Hendzel asked if we would be arresting the male. I asked Officer Onyx
what was actually in the backpack so we could make a determination for charges. He showed
me a plastic bag containing a dried material that appeared to be Psilocybin or "mushrooms".
There were also numerous green pills in various bags. These pills were later determined to be
Alprazolam, which is a schedule IV controlled substance. There was also a green leafy
substance in several different containers that appeared to be marijuana.

Preliminary Breath Test/Admissions of Distribution

During his contact with officers, ROBINSON-SELLERS informed us that he had consumed an
entire bottle of "Henny" by himself and that was the reason for his strange behavior. I had
Officer Onyx retrieve a PBT bag from the patrol vehicle and cycled it through a self-test. After
Officer Hendzel received a .000 reading, I stepped into the lounge to dispose of the straw.

When I returned, Officer Hendzel informed me that ROBINSON-SELLERS had just admitted
that he was going to be delivering the drugs to someone. At this point, we still had not been
able to identify him, so I went out to meet with Officer Onyx to determine if we had identified
the male. I also reexamined the contents of the backpack to determine quantity of the various
drugs and what the prescription pills were. Based on what was found, we decided we were
going to refer charges for the possession of the three items.

Consent Search
At this time, we decided to ask for a consent search of his dorm room to determine if he had
any more illegal substances in his room. ROBINSON-SELLERS gave us consent to search his
room and we walked over to that location. Upon arrival to his room, ROBINSON-SELLERS
was unable to gain access to his room because he forgot the code. After several attempts,
Officer Hendzel offered to key into his room. I initially told him not to because of the consent
issue, but ROBINSON-SELLERS said that it would be easier if we could let him in his room.
Officer Hendzel used the master housing key to unlock the door and then was about to let him
enter his room.

Discovery of Handgun/Scene Security

ROBINSON-SELLERS took one step forward to enter his room and a black handgun fell out of
the back of his jacket and onto the floor. He attempted to bend over and pick it up when Officer
Hendzel kicked the gun away and then pushed him away from the weapon and decentralized
him onto the ground. I assisted Officer Hendzel while Officer Onyx secured the firearm.
ROBINSON-SELLERS was handcuffed and then assisted to his feet. I took possession of the
firearm from Officer Onyx and secured the scene. I collected the cell phone and various cards
that were lying on the floor and secured them as well.

While on scene, I made contact with Chief Decker who immediately came to the campus and
began assisting with the search warrant writing. I also observed the name "Justin H" on the
door of room 302. I knocked on the door to see if anyone was home. No one answered so I
had Officer Onyx check with AD Lyndsey to see if anyone else lived in the room. She told me
the person (Justin) who used to live there had just moved out on February 4th.

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STATE OF WISCONSIN - VS - Joel Xaiver Robinson-Sellers

Officer Onyx returned to the scene and informed me they had also found a 29 capacity
magazine on ROBINSON-SELLERS. I took possession of this as well. I observed that it had
approximately 20 rounds of .40 caliber ammunition loaded in it.

Evidence
I returned to the UW-Green Bay Police department. Chief Decker requested I turn over the
handgun, magazine, and ammunition that were found on ROBINSON-SELLERS. I removed
the items from temporary evidence locker #6 and turned them over to him. The locker was re
secured.

I re-opened the locker at approximately 6:00 AM to remove the suspected marijuana for
testing. I weighed the substance before testing and found it weighed 7.37 grams. I utilized a
NARK II Duquenois-Levine Reagent test kit and followed the directions on the back of the box.
The test results indicated a positive result for the presence of THC.

2. Your Complainant’s review of the reports of Officer Onyx of the University of Wisconsin-
Green Bay Police Department, who indicates:

Upon my arrival I observed Joel sitting on the stairwell, next to Joel there were lighters, a
green leafy substance placed on the stairwell steps, and a black backpack. Joel informed us
that he was attempting to get to his room. Joel believed that he was in James Temp Hall.

Joel had Slurred speech, disorientation, loss of balance, rambling, or repetitive statements,
and was unable to determine which building he was in.

Officer Hendzel informed me that there was an illegal substance in the black backpack.

I searched the backpack I located the following items:

- A container with logo and writing stating Delta -10. With a green leafy substance.
- A plastic zip bag containing: a dry mushroom substance.
- A brown paper container: with a green leafy substance.
- Two zip bags containing multiple green tablets pills.

I asked Joel if he would consent to police officers searching his apartment. Joel granted
consent to the search of his apartment. Joel was escorted to the east side on the main
entrance of Donald Long, before exiting the building Joel began going up the stairwell in an
attempt to get to room 302. Joel was advised that the building that we were in is Donald Long
and he lived in James Temp Hall. Joel was escorted to James Temp Hall, room 302.

Upon arrival, Joel used his card key to enter his apartment room 302. Joel informed us that he
had forgotten his passcode to enter his apartment. While Joel attempted to open the door of
his apartment, A black handgun/ weapon fell from Joel's person. Officer Hendzel and SGT.
Duchateau decentralized Joel to the ground and I secured the handgun/weapon.

Joel was placed under arrest and escorted to officer Hendzel's patrol vehicle. An incident-to-
arrest search was conducted on Joel. I located a 29 rounds magazine, with approximately 15
live rounds in Joel's right jacket pocket. The magazine was secured. Joel was placed in the
back of officer Hendzel's patrol vehicle.

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STATE OF WISCONSIN - VS - Joel Xaiver Robinson-Sellers

Searched warrant approval:

When the search warrant was approved, officer Hendzel and I announced police, knocked in
the apartment, and waited a reasonable amount of time before entering apartment 302. The
apartment did not have any people inside.

I took photos of the room before searching the apartment, I assisted officer Hendzel and SGT
Duchateau in taking photos of the evidence found. Items found:
- A broken green pill was located on the restroom top cabinet. The restroom cabinet is
located outside the restroom.
- A brown leafy substance was on the restroom floor.
- A Green leafy substance in the bead cover sheet.
- A zip transparent bag with multiple green pills was located on the left side top cabinet of
a wooden desk.
- A black magazine inside a blue plastic bin.
- A 40-caliber bullet inside a black suitcase.

The following items were secured and taken as evidence:

- A broken green pill with was located on the restroom top cabinet is located outside the
restroom.
- A brown leafy substance on the restroom floor.
- A zip transparent bag with multiple green pills located on the left side top cabinet of a
wooden desk.

3. Your Complainant’s review of the reports of Officer Hendzel of the University of Wisconsin-
Green Bay Police Department, who indicates:

ON SCENE OBSERVATIONS
Sergeant Duchateau #747, Officer Onyx #749 and I arrived on scene and entered the building.
Once in the building, I checked the first floor for the male while the other officers checked the
second and third floor. I walked through the first floor and came in contact with a male sitting
on the stairs at the bottom of the staircase. The male was later identified as, Joel X.
Robinson-Sellers . The male was on the phone when I entered the room. Robinson-Sellers
was slurring his words and talking loudly over the phone. Next to Robinson-Sellers on the
stairs was a pile of green leafy substance, along with various lighters, headphones, and other
personal belongings. Through my training and experience I believed this green leafy substance
to be marijuana. When asked, Robinson-Sellers stated the green leafy substance was
marijuana, but it was not his. Robinson-Sellers later admitted that the marijuana was his, and
that he purchased it in Illinois where it was legal. Robinson-Sellers was informed that
marijuana is illegal in the state of Wisconsin.

CONTACT WITH ROBINSON-SELLERS

I asked Robinson-Sellers if he living in this building (3362 Schaefer Ct.) to which he replied
"yes". Robinson-Sellers stated he was waiting for a friend to come pick him up. I then
attempted to identify Robinson-Sellers, but he stated he did not have his identification on him.
Robinson-Sellers then began to reach into his backpack looking for his identification. Once
Robinson-Sellers began reaching inside of his backpack I asked him if I could take a look
inside of it to make sure there was" nothing in there that shouldn't be". Robinson-Sellers stated
"oh yeah you can check my bag". As he said this Robinson-Sellers opened his backpack and
held it out towards me showing me the open pocket containing money. The second

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STATE OF WISCONSIN - VS - Joel Xaiver Robinson-Sellers

compartment of the backpack was partly open and I was able to see into the main
compartment of the bag. In this section of the backpack, I was able to see a clear plastic bag
containing green pills. Through my training and experience as a law enforcement officer I
believed these to be prescription pills. As Robinson-Sellers held the backpack up towards me I
could also detect what I know to be the strong odor of marijuana coming from the backpack. At
this time, the backpack was placed off to the side so I could focus my attention on Robinson-
Sellers. Roughly one min later, while attempting to locate Robinson-Sellers's identification I
opened up the main compartment of the backpack. In this main compartment I found multiple
clear zip lock bags containing green pills, and a clear jar containing a green leafy substance.
At this time, I notified Robinson-Sellers that I would not be returning the bag to him, as it was
filled with illegal drugs. Robinson-Sellers stated that the pills in the backpack were his
prescription pills from home, and that the prescription pill bottle was in his dorm room.
Robinson-Sellers stated that he was shot twice in Chicago and his doctor prescribed the
medication to him after.

I then began to ask Robinson-Sellers about the door he was knocking on the 3rd floor.
Robinson-Sellers stated he was not knocking on the door, and that it was someone else
running around the second floor. Robinson-Sellers stated he lived in 3362 Schaefer Ct. room
#302 and he was trying to get into his room. Robinson-Sellers stated he believed he was in
"James Temp Hall", when actually he was currently in Donald Long Hall. It was discovered that
Robinson-Sellers actually lived in 3366 Schaefer Ct. #302 and that he was in the wrong
building. Robinson-Sellers then changed his story and stated he was in James Temp Hall to
meet up with a friend.

At this time a University Housing staff member approached me and handed me two credit
cards, and a student identification that belonged to Robinson-Sellers. When asked, she stated
that she found the items on the end of a window in James Temp Hall. Robinson-Sellers's
student identification was used to confirm his identity at this time.

At this time, Robinson-Sellers was frisked by officer Onyx and I to check for any additional
drugs on his person. No other items were found at this time.

Due to the fact that Robinson-was slurring his words, and could not keep his story straight I
questioned him on whether or not he had been drinking or taken any pills. Robinson-Sellers
stated he does not drink, but had smoked earlier that night. Later in my contact with Robinson-
Sellers he stated he consumed a whole bottle of "Hennessy" by himself. Robinson-Sellers
voluntarily took a Preliminary Breath Test (PBT) and the results came back as 0.00. Robinson-
Sellers later admitted to consuming both THC and prescription pills.

During my contact with Robinson-Sellers he was taking pictures of officers, and making phone
calls to friends. For this reason, I asked Robinson-Sellers if I could hang on to his phone.
Robinson-Sellers gave me his phone to hang onto while I was talking to him.

Robinson-Sellers then changed his story again stating that he was at a friend "Angelina's when
he realized he forgot his drugs. Robinson-Sellers stated that they came back to retrieve his
drugs and that's when the police arrived. Robinson-Sellers stated he was picking up the drugs
then going to meet a friend names "Hussein" to bring them to him. When asked if he was
delivering the drugs to Hussein he stated no he was bringing them there so everybody could
have some. Later in my contact with Robinson-Sellers he changed his story and stated he was

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STATE OF WISCONSIN - VS - Joel Xaiver Robinson-Sellers

bringing the drugs to Chicago. I asked Robinson-Sellers if he was bringing the drugs to
Chicago to sell them, to which he replied no.

At this time, Officer Onyx returned and asked Robinson-Sellers if he would give us permission
to search his room for any additional drugs to which he replied "yes". Sergeant Duchateau,
Officer Onyx and I escorted Robinson-Sellers back to his room located at 3366 Schaefer Ct.
#302. Once at Robinson-Sellers's door he attempted to gain entry on his own room with his
student ID, but was unable to gain access as he didn't remember his pass code. I told
Robinson-Sellers that I could open his door for him if he gave me permission. Robinson-
Sellers gave me permission to unlock his room for him. After I unlocked Robinson-Sellers's
door I told him he could enter his room. When I told Robinson-Sellers this he turned to two
males walking down the hall to say hi to them. As Robinson-Sellers did this, a black handgun
fell to the ground at feet. When this happened, I immediately decentralized Robinson-Sellers
and escorted him to the ground while yelling "get on the ground". Robinson-Sellers was put in
handcuffs and placed under arrest. Officer Onyx and I escorted Robinson-Sellers to squad
#87. As Robinson-Sellers was being escorted to the squad car he slipped on the ice, but
officers caught him before he hit the ground. Robinson-Sellers was asked if he was alright to
which he replied "yes". Officer Onyx and I searched Robinson-Sellers at the squad car where
Officer Onyx located a 29 round extended capacity pistol magazine. Robinson-Sellers was
then secured in the back of the squad car.

INTERVIEW OF ROBINSON-SELLERS
Robinson-Sellers was transported back to the University of Wisconsin Green Bay Police
Department for further interviewing. Robinson-Sellers was placed in the interview and
monitored via CCTV footage until he was interviewed.

Sergeant Duchateau and I interviewed Robinson-Sellers. I read Robinson-Sellers his Miranda

rights prior to the interview. Robinson-Sellers stated he understood his rights and agreed to
talk to officers.

I asked Robinson-Sellers where he had gotten the handgun. Robinson-Sellers stated he got
the gun in Chicago, but would not give any other information regarding how he got the firearm.
Robinson-Sellers stated he knows handguns are not allowed on campus, as he saw a sign on
the dorm stating no weapons. Robinson-Sellers stated he normally does not carry the gun on
him outside of Chicago. Robinson-Sellers stated he has the gun for his own protection, as he
has been shot in the past. Robinson-Sellers stated he went to his aunt's house on Friday to
pick up the gun before he went out to party and wanted it for protection. Robinson-Sellers
stated he was going to leave the gun at a relative's house later tonight, but got arrested first.
Robinson-Sellers provided officers with a name of "Backanka Stokes" who is a relative in town.
Robinson-Sellers stated he normally keeps the gun here and retrieves it when he needs it.
Robinson-Sellers did not provide any additional information about the firearm or drugs during
my interview with him.

SEARCH OF ROBINSON-SELLERS'S APARTMENT

Officer Onyx and I met Sergeant Duchateau at 3366 Schaefer Ct. to perform a search of
Robinson-Sellers's residence. Officer Onyx and Sergeant Duchateau took turns remaining
outside of room #302 prior to the search ensuring nobody had entered the residence. Officers
knocked on the door multiple times announcing "Police Department Search Warrant" before
entering the room. Once in the room Officer Onyx took pictures and collected evidence as

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STATE OF WISCONSIN - VS - Joel Xaiver Robinson-Sellers

Sergeant Duchateau and I searched the room. The search of Robinson-Sellers's apartment
resulted in officers finding more evidence.

I, Officer Hendzel, located a small amount of what appeared to be burnt marijuana on the floor
of the bathroom. Also recovered was a small piece of a green pill located on the vanity outside
the bathroom. Officers also located a small clear plastic bag containing more of the small
green pills. This bag of pills was located in the top left drawer of a desk containing Robinson-
Sellers's belongings. While searching one of the suitcases under Robinson-Sellers's I located
a single .40 caliber red tip bullet in the bottom of the suitcase under some clothes. Lastly,
Sergeant Duchateau located a handgun magazine in a blue tote also located under the bed. A
copy of the search warrant was left in the room after the search was completed. All evidence
was photographed and collected by Officer Onyx as it was found during the search. Officers
also confiscated Robinson-Sellers's phone, as it will be processed for any evidence it may
have on it.

Based on the foregoing, the complainant believes this complaint to be true and correct.

Subscribed and sworn to before me on Electronically Signed By:

02/08/23 Meranda Hillmann
Electronically Signed By: Complainant
Eric R Enli
Assistant District Attorney
State Bar #: 1020873

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