Sentencing Memo For Steven Zamiar 4h476r

Case: 1:13-cr-00929 Document #: 106 Filed: 09/25/15 Page 1 of 19 PageID #:1369

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES OF AMERICA v. STEVEN G. ZAMIAR

) ) No. 13 CR 929 ) ) Judge Sharon Johnson Coleman )

GOVERNMENT’S SENTENCING MEMORANDUM The United States of America, by its attorney, Zachary T. Fardon, United States Attorney for the Northern District of Illinois, submits this memorandum in advance of the sentencing of defendant Steven G. Zamiar, who was found guilty by a jury beyond a reasonable doubt of excessive use of force with a dangerous weapon under color of law, resulting in bodily injury to the victim. The government respectfully submits that a sentence within the advisory Guidelines range of 87 to 108 months’ imprisonment is appropriate in this case. I.

INTRODUCTION Defendant Zamiar was a highly successful police officer. At the height of his

career, immediately prior to being charged in this case, he was Deputy Chief of Police for the Midlothian Police Department, a position that made him second in command of the department with supervisory authority over its police officers. Trial in this case focused on Zamiar’s arrest of James Snyder on November 23, 2011. During that arrest, Zamiar used excessive and unreasonable force when he beat Snyder with a metal police baton, repeatedly striking him in the head, neck, and spine. Adding insult to injury, Zamiar directed his subordinate police officers on the scene to arrest Snyder and take him into custody.


At his first opportunity for contrition—back at the police station—Zamiar did not it his mistake; he lied about it.

He told one officer that he swung for

Snyder’s legs and missed, he prepared a false use-of-force form asserting facts that were untrue, and he repeated those lies on a second police report, this one a level-ofresistance report. Trial in this case was his second opportunity for contrition. But instead of accepting responsibility for his crime, Zamiar consciously sought to obstruct justice. He deliberately took the stand at trial where, under oath, he lied to the jury about critical facts. Moreover, the government’s continued investigation has revealed that Zamiar’s actions on the night of November 23, 2011, and at trial were no aberration. He has violated other individuals’ civil rights and has gained notoriety within the Midlothian Police Department as an unethical and corrupt police officer. A fair and just sentence in this case will for Zamiar’s history and characteristics, including his repeated civil rights violations and obstruction of justice, as well as the need to deter other law enforcement officers from engaging in the same or similar type of conduct. A sentence of 87 to 108 months’ imprisonment is sufficient, but not great than necessary, to accomplish those goals. II.

BACKGROUND A.

Defendant’s Offense Conduct

On the night of November 23, 2011, Zamiar was conducting surveillance of Durbin’s Bar in Midlothian, Illinois, from across the street when he saw a large crowd of people outside. Zamiar called out to his fellow Midlothian police that there was a fight at Durbin’s, even though he did not see a fight. Zamiar then drove to 2


Durbin’s, parked his unmarked car, walked up to the bar, and stood in the front beer garden. When a Durbin’s bouncer looked out the glass window from inside the bar, as he testified at trial, he saw a man (Zamiar) holding an extended police baton. That the Zamiar was standing outside the bar with an extended metal police baton is telling; Zamiar was primed for a fight and looking for an opportunity to use the baton. The bouncer approached Zamiar —who was wearing plainclothes with no outwardly visible police markings—and Zamiar responded by pulling out his police badge, identifying himself as a police officer. After walking through the beer garden and not finding anyone to arrest, Zamiar went to an adjacent parking lot where he saw a bar patron, James Snyder, entering a car driven by his girlfriend. Zamiar approached, but did not show his police badge, or otherwise identify himself as a police officer. Instead, Zamiar took a deadly and dangerous weapon—his metal police baton—and lunged. Snyder—faced with a man armed with a deadly weapon—turned and ran for help. As Snyder ran back towards the bar, Zamiar repeatedly struck Snyder with a metal police baton across the back of Snyder’s head, neck, and back, leaving large welts, red marks, and bruises. These welts, marks, and bruises are evident in the photographs of Snyder’s back and head that the government introduced at trial, taken several hours after the incident

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Defenseless, Snyder tried to block the swings to no avail. Zamiar chased Snyder through the Durbin’s parking lot as Snyder ran to other Midlothian police officers for help. Snyder then hid behind one of the police officers and tried to shield himself from any further attack by Zamiar. Zamiar walked up to those other officers and instructed them to “arrest this asshole.” Back at the police station, Zamiar proceeded to lie to cover up his mistake. He told another officer that he was swinging with his baton for Snyder’s legs, but missed. Zamiar prepared a police report from the incident, falsely claiming that Snyder “turned toward me in an aggressive manner,” leading Zamiar to have to “utilize[] my ASP baton.” Defendant also prepared a “Level of Resistance/Response Report,” which falsely stated that Snyder engaged in “active resistance” to arrest. B.

Defendant’s False Testimony At Trial

During trial, Zamiar chose to testify in his own defense. He took the witness stand, swore an oath to tell the truth, and proceeded to tell lie after lie to the Court 5


and to the jury. He lied in an effort to convince the jury that Snyder—not him —was the aggressor that night and to portray himself as simply a police officer trying his best to do his job. The jury was not convinced, finding Zamiar guilty of intentionally depriving Snyder of his civil rights in violation of 18 U.S.C. § 242. This Court, too, should not be convinced; what Zamiar did was obstruct justice, plain and simple. Zamiar’s lies began on direct examination when he testified about his encounter with the bouncer outside Durbin’s Bar. When asked what he did when he approached the bar, Zamiar testified that he “made with an individual I’d seen pushing them [bar patrons] out, who I knew to be a bouncer or security at the bar.” Tr. 450. When asked if he had anything in his hand at that point, Zamiar testified, “I don’t believe so, but maybe a flashlight, you know.” Id. Zamiar was then asked, “Did you have your baton out?” Zamiar responded, “No.” Id. This testimony was directly contradicted by the unimpeached testimony by the bouncer, who testified that he clearly recalled that the object in Zamiar’s hand was a baton, approximately nine to sixteen inches long. See Tr. 356. Zamiar’s lies continued throughout his direct and cross-examination:  When asked what he observed in the Krispy Kreme parking lot, Zamiar falsely testified, “They [Snyder and Burns] closed the distance, and Mr. Snyder threw a punch.” Tr. 471.  When asked what happened after the punch was thrown, Zamiar falsely testified that he identified himself as a police officer, testifying that, “I yelled, ‘Hey, police.’” Tr. 471. This is contradicted by the testimony, credited by the jury, of Snyder and his girlfriend.  Zamiar then testified that he chased Snyder up an embankment towards Durbin’s. Zamiar falsely testified that Snyder—defying the laws of physics and common sense—stopped on a dime with Zamiar a step or two behind him, and took a fighting stance: “Once … we were up the hill on a flat surface, Mr. Snyder 6


stopped abruptly and turned back towards me with his hands in the air.” Tr. 474.  Zamiar falsely testified that he did not strike Snyder in the head and neck with a police baton. Tr. 475. This testimony was flatly contradicted by the photographs of Snyder’s head taken immediately after the incident, Snyder’s testimony, the testimony of one of Zamiar’s own fellow officers, and the attending paramedic.  Zamiar falsely testified that he struck Snyder three times with his baton, once in the arm and twice to the back. Tr. 475-80. This testimony was flatly contradicted by Snyder’s testimony, the testimony of another Midlothian police officer on the scene, and the photographs of Snyder’s back and neck, showing multiple (between nine and twelve) welts and strike marks.  Zamiar falsely testified that another officer gave the order to arrest Snyder. Tr. 480. This testimony, yet again, was flatly contradicted by the unimpeached testimony of the Durbin’s bouncer, Snyder, and another officer on the scene. Each of Zamiar’s lies was intentional, calculated, and material to the jury’s determination of guilt. By falsely testifying that he saw Snyder throw a punch in the parking lot and that Snyder turned towards him in an aggressive manner, Zamiar attempted to manipulate the jury into believing that he had a reasonable basis to use force when, in fact, his actions were unjustified and excessive. III.

DEFENDANT HAS A HISTORY OF CIVIL RIGHTS VIOLATIONS On at least two prior occasions, Zamiar violated other citizens’ constitutional

rights under the Fourth Amendment during arrests. Detail, including sworn witness statements and photographs, regarding those incidents was provided to the Court and Probation Officer as part of the Government’s Version of the Offense, dated June 3, 2015, and the Supplement to the Government’s Version of the Offense, dated July 31, 2015.

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The government submits that this evidence is relevant to the Court’s consideration at sentencing. Title 18, United States Code, Section 3661 provides that, “No limitation shall be placed on the information concerning the background, character, and conduct of a person convicted of an offense which a court of the United States may receive and consider for the purpose of imposing an appropriate sentence.” 18 U.S.C. § 3661. It is well established that the Court may consider criminal conduct, as relevant to defendant’s personal history and characteristics and the need for deterrence, even where that conduct was not charged—in fact, this rule holds even where the conduct was charged but the defendant was acquitted of it. See, e.g., United States v. Watts, 519 U.S. 148, 152-53 (1997) (“[W]e are convinced that a sentencing court may consider conduct of which a defendant has been acquitted.”); United States v. Carter, 111 F.3d 509, 514 (7th Cir. 1997) (charges on which a defendant was acquitted or for which charges were dismissed can be considered at sentencing so long as the government’s evidence is reliable); United States v. Fonner, 920 F.2d 1330, 1333 (7th Cir. 1990) (a sentencing court can consider past conduct, even if defendant was acquitted, as long as conduct is established by a preponderance of the evidence). The evidence provided to the Court, though hearsay, is sufficiently reliable and corroborated for the Court to consider and find Zamiar’s prior use of excessive force to be proven by a preponderance of the evidence (the relevant standard at sentencing). See, e.g., United States v. Salutric, 775 F.3d 948 (7th Cir. 2015); United States v. Jones, 635 F.3d 909, 917 (7th Cir. 2011) (“In arriving at an appropriate

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sentence, a judge may appropriately conduct an inquiry broad in scope, largely unlimited as to the kind of information he may consider, or the source from which it may come.” (internal quotation marks and citations omitted); United States v. Neal, 662 F.3d 936, 938-939 (7th Cir. 2011) (“The district judge properly considered [the defendant's] history and character, noting that he smoked marijuana on a daily basis in the past, had used illegal substances in 1999 and 2000 before he was arrested, and had used cocaine prior to his incarceration.”). The specifics of each incident, and the reliability of the ing evidence, are discussed in turn below: A.

Defendant Used Excessive and Unnecessary Force During an Arrest on November 16, 2009.

On November 16, 2009, Zamiar participated in the arrest of a person suspected of having been involved in a bank robbery. After the suspect was handcuffed and laying on the ground, Zamiar walked up to the suspect and kicked the suspect at least twice in the face. Zamiar’s kicks to the suspect’s head were excessive and unnecessary. The suspect did not do anything during arrest that would justify the level of force Zamiar used, particularly when the suspect was laying on the ground handcuffed. The suspect suffered cuts and bruising to his nose as a result of Zamiar’s kicks. At the time of the incident, Zamiar held the rank of Detective Sergeant within the Midlothian Police Department; his actions were witnessed by two subordinate officers. The evidence proving that this incident occurred is reliable. Attached as exhibits to the Supplement to the Government’s Version of the Offense are:

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(a) photographs of the arrestee’s face, reflecting bruises, swelling, and cuts in the area of the nose, which are consistent with the strikes from a shoe or boot; (b) the sworn statements of two law enforcement officers who witnessed the incident, both of whom are currently employed by the Midlothian Police Department and, like the victim, have no incentive to lie; and (c) a report prepared by an FBI special agent, summarizing his interview of the victim-arrestee while that person was in custody at Cook County Jail. B.

Defendant Used Excessive and Unnecessary Force During an Arrest on September 6, 2010.

On September 6, 2010, Midlothian police officers arrested two males suspected of burglarizing and vandalizing vehicles in Zamiar’s neighborhood. When one suspect was apprehended, Zamiar approached that suspect, stood over him, and threw closed-fist punches repeatedly at his head and face. There was no lawful or legitimate reason for Zamiar to use the level of force he did against that suspect. At the time of the incident, Zamiar held the rank of Detective Sergeant within the Midlothian Police Department; his actions were witnessed by a subordinate officer. Just as Zamiar lied following the incident on November 23, 2011, and just as Zamiar lied at trial in this case, Zamiar lied to the Federal Bureau of Investigation when asked questions about the incident on September 6, 2010. In February 2013, two FBI agents approached Zamiar at his home and asked him questions about the incident on September 6, 2010. Zamiar stated that the suspect fought back during the arrest—contrary to the statement of Zamiar’s fellow officer who witnessed the incident. When asked if one of the officers laid hands on the suspect, Zamiar refused

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to answer. Zamiar then stated that the suspect had a black eye (neither of the two agents mentioned the black eye and had not shown Zamiar a picture of the suspect with a black eye). When asked how the suspect got the black eye, Zamiar falsely stated that he did not know. Zamiar incredulously suggested that maybe the suspect ran into a tree. Agents then asked Zamiar who hit the suspect. Zamiar twice responded that neither he nor the other officer hit the suspect, again contrary to the reliable evidence, including the sworn statements of Zamiar’s fellow officer and the victim himself. The evidence proving that this incident occurred is reliable. Attached as exhibits to the Government’s Version of the Offense are: (a) the sworn testimony of the victim-arrestee regarding the incident; (b) the sworn testimony of a Village of Midlothian police officer who witnessed Zamiar beat the victim-arrestee; (c) the sworn testimony of a Village of Midlothian police officer who saw Zamiar in the immediate aftermath of the beating; (d) photographs of the victim-arrestee’s face; and (e) an FBI report of interview, summarizing FBI special agents’ interview of Zamiar regarding the incident. IV.

THE PRESENTENCE INVESTIGATION REPORT The government concurs in the Probation Officer’s determination regarding

the base offense level and applicable enhancements. A.

The Base Offense Level Is 14.

The Probation Officer correctly concluded that the base offense level is 14 by reference to Guideline § 2A2.2, which governs aggravated assault. Specifically, Guideline § 2H1.1 covers offenses involving civil rights violations. Pursuant to 11


§ 2H1.1(a)(1), the applicable offense level is the “offense guideline applicable to any underlying offense.” As defined in Application Note 1, that means “any conduct established by the offense of conviction under federal, state, or local law.” In this case, the jury concluded beyond a reasonable doubt that Zamiar’s use of excessive force resulted in Snyder’s bodily injury and that defendant’s actions included the use of a dangerous weapon. That fits within the definition of an aggravated assault, which is “a felonious assault that involved (A) a dangerous weapon with intent to cause bodily injury (i.e., not merely to frighten) with that weapon; (B) serious bodily injury; (C) strangling, suffocating, or attempting to strangle or suffocate; or (D) an intent to commit another felony.” U.S.S.G. § 2A2.2, note 1. B.

There Is a Seven-Level Increase Because Zamiar Caused Bodily Injury and Used a Dangerous Weapon.

The Probation Officer correctly concluded that, pursuant to Guideline § 2A2.2(b)(2)(B), Zamiar’s offense level is increased four levels because “a dangerous weapon … was otherwise used” during the offense. This is consistent with the jury’s finding and with the evidence presented at trial. A metal police baton falls well within the definition of a dangerous weapon, which is “an instrument capable of inflicting death or serious bodily injury.” U.S.S.G. § 1B1.1, note 1(D). As Midlothian Police Officer Thibo testified at trial, a metal police baton is a dangerous weapon that is capable of causing death and spinal injury if used to strike a person in the head, neck or back. See Tr. 120 (“You can cause severe, permanent injury to somebody by striking them in the head, neck, or spine, or actually, death.”).

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The Probation Officer also correctly concluded that, pursuant to Guideline § 2A2.2(b)(3)(A), defendant’s actions caused “bodily injury,” which is defined by that Guideline as an injury that is painful and obvious, or is of a type for which medical attention ordinarily would be sought.” See also United States v. Ashley, 141 F.3d 63, 68 (2d Cir. 1998) (“This definition [of serious bodily injury] appears to encom a wide range of injuries such as broken bones or other nonpermanent wounds that require ‘medical intervention such as surgery, hospitalization, or physical rehabilitation.’”). In this case, Snyder testified that he suffered contusions and welts on his head, neck, arm, and back as a result of Zamiar’s assault, corroborated by the photographs introduced by the government as exhibits at trial, and he sought medical treatment for his injuries at the police station and also at the hospital. As a result, an additional three-level increase to the offense level was appropriately included. C.

There Is a Six-Level Increase Because Defendant Acted Under Color of Law.

The Probation Officer correctly concluded that Zamiar acted under color of law, warranting a six level increase to the offense level under Guideline § H1.1(b)(1)(B). At the time of the incident, Zamiar was on duty as a police officer holding the rank of Deputy Chief of Police, and he committed the offense under color of law as a sworn Midlothian police officer. D.

There is a Two-Level Increase Because Defendant Obstructed Justice at Trial.

The Probation Officer correctly concluded that Zamiar receives a two-level enhancement under Guideline § 3C1.1 because he attempted to obstruct justice at 13


trial by falsely testifying about material facts while under oath on the stand. In addition, defendant prepared two materially false reports in the hours after the incident, each of which falsely stated that Snyder’s injuries were attributable to his own aggressive conduct; this, too, warrants the enhancement. E.

Defendant Is Not Entitled to a Three-Level Reduction for Acceptance of Responsibility.

The Probation Officer correctly concluded that Zamiar does not receive a downward adjustment for acceptance of responsibility. Not only did Zamiar put the government to its burden at proof and deny essential factual elements of guilt, but he also falsely testified at trial. 1 This is a clear case of a defendant failing to accept responsibility for his criminal conduct; therefore no reduction is appropriate. V.

A SENTENCE WITHIN THE ADVISORY GUIDELINES RANGE IS APPROPRIATE IN THIS CASE. With placement in Criminal History Category I and an offense level of 29,

Zamiar has an advisory Guidelines range of 87 to 108 months’ imprisonment. This case presents sufficiently compelling reasons to sentence Zamiar within that range under 18 U.S.C. § 3553(a), 2 particularly in light of his history of civil rights

The commentary to Guideline § 3E1.1 explains that an adjustment for acceptance “is not intended to apply to a defendant who puts the government to its burden of proof at trial by denying the essential factual elements of guilt, is convicted, and only then its guilt and expresses remorse.” USSG § 3E1.1 (comment, n.2). Moreover, “[c]onduct resulting in an enhancement under § 3C1.1 (Obstructing or Impeding the istration of Justice) ordinarily indicates that the defendant has not accepted responsibility for his criminal conduct.” USSG § 3E1.1 (comment, n.4). 1

Sentencing has four purposes: retribution; deterrence; incapacitation; and rehabilitation. See United States v. Milbourn, 600 F.3d 808, 812 (7th Cir. 2010). Title 18, United States Code, Section 3553(a), sets forth the facts courts are to consider in fashioning a sentence that is sufficient but not greater than necessary to comply with these purposes. First, however, the Court must calculate the applicable Guidelines range, which provides a

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violations, his efforts to cover up his criminal conduct from the Midlothian Police Department, his lies to the FBI, his obstruction of justice at trial, and the need to deter other law enforcement officers from engaging in similar conduct. A.

The Seriousness of the Offense

The seriousness of the offense defendant committed—a criminal violation of a citizen’s civil rights by a sworn police officer—cannot be understated. When Zamiar assaulted Snyder outside Durbin’s bar, he certainly caused serious injuries to Snyder. Zamiar’s strikes with his steel baton to Snyder’s head, neck, and back easily could have left Snyder paralyzed or even dead. Even apart from the severity of the physical wounds, Zamiar’s baton strikes have significant ramifications for the criminal justice system. Sworn law enforcement officers are held to a higher standard of conduct, not merely because of the authority that they enjoy, but because society relies on their trustworthiness, their honor, and their integrity in upholding and enforcing the laws that protect the community. With each baseless and unnecessary baton strike in front of that crowd of people outside Durbin’s Bar, Zamiar gave the Midlothian community every reason to believe that police officers could not be trusted, that police officers were aggressive, and, worst of all, that police officers were abusive. As the Court is all too

starting point and initial benchmark for sentencing. Gall v. United States, 552 U.S. 38, 4950 (2007); see also 18 U.S.C. § 3553(a)(4). Next, the Court must consider the other § 3553(a) factors. United States v. Omole, 523 F.3d 691, 697 (7th Cir. 2008). These factors include the need “(A) to reflect the seriousness of the offense, to promote respect for the law, and to provide just punishment for the offense; (B) to afford adequate deterrence to criminal conduct; (C) to protect the public from further crimes of the defendant; and (D) to provide the defendant with needed educational or vocational training, medical care, or other correctional treatment in the most effective manner.” 18 U.S.C. § 3553(a)(2)(A)-(D). 15


well aware, bad police officers—like bad apples—tend to spoil the bunch, making a difficult job all the more difficult for police officers while straining the relationship and balance between the police and the community. Compounding the injuries inflicted outside Durbin’s, Zamiar came to this Court, swore an oath, and then lied to a jury of his peers—people who will go back to the community knowing that the Deputy Chief of Police from a local community was willing to lie through his teeth at a federal criminal trial. Zamiar’s actions— both outside Durbin’s Bar and in the courtroom—make it more difficult for law enforcement officers, including those from the Village of Midlothian, to do their job well, and undermine the community’s trust. B.

The Need for Deterrence

The Village of Midlothian meted out a certain level of specific deterrence by suspending Zamiar from duty following the initiation of federal charges and then subsequently removing him from the police force. But this case brings with it a unique opportunity for the Court to reinforce to the community, and especially the law enforcement community, that violating citizens’ constitutional rights and then lying to cover up those crimes are very serious offenses that will be prosecuted and punished to the fullest extent of the law. Not only do stiff sentences send such a message to the community, but they also make it clear that law enforcement officers will be held able just like any other criminal defendant if they violate the law.

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C.

The Defendant’s History and Characteristics

At the time of the charged offense, Zamiar was a trained and experienced police officer who held a clear position of authority with the police department. In fact, Zamiar had been a police officer since approximately 1997 and, throughout the years, had attended a number of training sessions on proper use of force—a fact that was thoroughly established at trial. That Zamiar committed this offense near the pinnacle of his career is not a saving grace for him. To the contrary, it exposes Zamiar’s cavalier attitude and arrogance that led him three times, beginning in 2009 and continuing through 2011, to egregiously violate the constitutional rights of of the community. The government acknowledges that it is likely true that, throughout Zamiar’s career, he experienced the daily stresses of a being a police officer, which undoubtedly can be a difficult job. This is absolutely no excuse for his behavior. If anything, the reactions of Zamiar’s fellow police officers speak volumes about Zamiar’s lack of character and unethical behavior. In the statements provided to the Court, one officer described specific instances of unethical behavior by defendant that he witnessed; another officer described Zamiar as a “bad dude” who would have “jammed” up the officer had the officer disclosed what happened when Zamiar beat an arrestee; a third described Zamiar as hyper, aggressive, and out of control as a police officer; and a fourth described Zamiar as “devious” and “not trustworthy.”

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VI.

CONCLUSION The government respectfully submits that, under 18 U.S.C. § 3553(a),

defendant has earned himself a sentence of 87 to 108 months’ imprisonment in this case. Respectfully submitted, ZACHARY T. FARDON United States Attorney By:

Dated: September 25, 2015

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/s/ Patrick M. Otlewski PATRICK M. OTLEWSKI ANDRIANNA D. KASTANEK Assistant United States Attorneys 219 South Dearborn, Fifth Floor Chicago, IL 60604 (312) 353-5300


CERTIFICATE OF SERVICE The undersigned Assistant United States Attorney hereby certifies that in accordance with FED. R. CRIM. P. 49, FED. R. CIV. P. 5, LR 5.5, and the General Order on Electronic Case Filing (ECF), the following document: GOVERNMENT’S SENTENCING MEMORANDUM was served pursuant to the district court’s ECF system as to ECF filers on September 25, 2015. Respectfully submitted, ZACHARY T. FARDON United States Attorney By:

/s/Patrick M. Otlewski PATRICK M. OTLEWSKI Assistant United States Attorney 219 South Dearborn Street, 5th Floor Chicago, Illinois 60604 (312) 469-6045

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