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Case 1:23-cr-00092-KWR Document 2 Filed 01/25/23 Page 1 of 3

*,*ar#*tffiff*,**,
IN THE LINITED STATES DISTzuCT COURT JANZSZrJn
:

FOR THE DISTRICT OF NEW MEXICO fld,TCHELL


H. eLFERS
CII-ERK
LINITED STATES OF AMEzuCA, )
)
Plaintiff, ) CRIMINAL NO.
)
vs. ) Count 1: 18 U.S.C. $ 242: Deprivation of
) Rights Under Color of Law;
MARQUET JOHNSON, )
) Count 2: t8 U.S.C. $ 92a(c)(1)(A)(ii):
Defendant. ) Using, Carrying, and Brandishing a Firearm
) During and in Relation to a Crime of
) Violence, and Possessing and Brandishing a
) Firearm in Furtherance of Such Crime.

INDICTMENT
The Grand Jury charges:

Einführung

At all times relevant to this Indictment:

l. The defendant, MARQUET JOHNSON, worked as a prisoner transport officer for

Inmate Services Corporation ("ISC").

2. Local jails and prisons throughout the United States of America hired ISC to

transport individuals who were arrested pursuant to out-of-state warrants.

3. The defendant, MARQUET JOHNSON, transported these individuals to the

jurisdictions that initially issued the wanants.

4. The defendant, MARQUET JOHNSON, by virtue of working as a prisoner

transport offrcer for ISC, was required to act in compliance with federal, state, and local laws,

including the United States Constitution.


Case 1:23-cr-00092-KWR Document 2 Filed 01/25/23 Page 2 of 3

5. T.P. was a female in custody, arrested on an out-of-state warrant, whom the

defendant, MARQUET JOHNSON, while acting as a prisoner transport officer, transported from

Santa Fe, New Mexico to De1ta County, Colorado.

6. Paragraphs One through Five are incorporated by reference in the counts below.

Count One

7. On or about November 4, 2019, in Bernalillo County, in the District of New

Mexico, the defendant, MARQUET JOHNSON, while acting under color of law, willfully

deprived T.P. of her fundamental right to bodily integrity, a riglrt secured and protected by the

Constitution and laws of the United States, when he penetrated T.P.'s vulva with his penis without

her consent and without a legitimate law enforcement pu{pose, and the defendant's conduct

included the use ofa dangerous weapon and aggravated sexual abuse.

In violation of 1 8 U.S.C. 9 242.

Count Two

8. On or about November 4, 2019, in Bemalillo County, in the District of New

Mexico, the defendant, MARQUET JOHNSON, knowingly used, carried, and brandished a

firearm, during and in relation to a crime of violence for which the defendant may be prosecuted

in a court of the United States, to wit: the wilIful deprivation of T.P.'s right to bodily integrity

under color of law, including the use of a dangerous weapon and aggravated sexual abuse, as

charged in Count 1 of this indictment, and in furtherance of such crime of violence, possessed and

brandished said firearm.

In violation of 18 U.S.C. $ 924(c)(1)(Axii).


Case 1:23-cr-00092-KWR Document 2 Filed 01/25/23 Page 3 of 3

A TRUE BILL:

lt*: i
FoREPERSON dT THE GRAND JURY

ALEXANDERM.M. UBALLW

Y BRAWLEY
United States AttorneY

KRISTEN M. CLARKE
Assistant Attomey General
Civil Rigtrts Division, U.S. Department of Justice

Trial Attomey
Criminal Section, Civil Rights Division

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