The documented evidence in 2016OPA-1167 reveals a systematic pattern of Fourth Amendment violations stemming from the deliberate falsification of police reports that transformed an initial finding of no violation into fabricated criminal charges. This case presents one of the most egregious examples of police report manipulation in the documented chain of custody from Edmonds Police Department to King County Sheriff's Department to Seattle Police Department, ultimately resulting in unlawful custodial detention based on entirely fabricated evidence.
Edmonds Police Officer Samuel Gagner (#2899) conducted the initial investigation in report 2016-00009660 and made the following critical determinations[1]:
"I confirmed that there is an active order of protection in place between Chard and Nuno, however, since Nuno did not attempt to contact Chard or have another party contact her on his behalf, there was no violation of the order"[1]
Officer Gagner further documented Danielle Chard's mental state, noting that he "provided her with a domestic resource pamphlet and took a statement from Chard for further evidence of Chard's erratic behavior for future court proceedings"[1]. This establishes that the originating law enforcement officer found no probable cause for criminal charges and specifically documented concerns about the complainant's reliability.
As the report moved through the law enforcement chain—from Edmonds to King County Sheriff's Department to Seattle Police Department—the fundamental facts were completely reversed[1]. The final Seattle Police report GO2016-148053 authored by Officer Erik Eastgard (#8348) now claimed[2]:
"vChard showed me an email containing a PDF file of a police report. vChard advised the email is from sNuno. The email was addressed from [email protected]"[2]
This transformation is constitutionally significant because:
Under Beck v. Ohio, 379 U.S. 89 (1964), probable cause requires "facts and circumstances within the officer's knowledge that are sufficient to warrant a prudent person, or one of reasonable caution, in believing, in the circumstances shown, that the suspect has committed, is committing, or is about to commit an offense"[6].
The evidence demonstrates a complete absence of probable cause: