Canyon Abuse Doc

JL FILED ~:c-:-- WtJGED RECEIVEB GO""

AUG 3 0 2011

United States District Court CLERKUSDISTRICTCOURT DISTRICT OF ARIZONA

-------DISTRICTOF ARIZONA :;' DEPUTY

REDACTED UNITED STATES OF AMERICA CRIMINAL COMPLAINT

V. Christopher Carlson CASE NUMBER:

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I, Christopher A. Smith, the undersigned complainant, being duly sworn, state the following is true and correct to the best of my knowledge and belief.

Countl

On or about August 15,2011 in Grand Canyon, Arizona, Coconino County, within the confines of Grand Canyon National Park, an area within the special maritime and territorial jurisdiction of the United States, the defendant, Christopher Carlson, under circumstances likely to cause death or serious bodily injury, did knowingly cause the health of John Doe 1 (a twelve old male), a child who was under his care, custody and control, to be injured or placed in situation in which the health of John Doe 1 was endangered, in violation of Title 18 United States Code, Section 13 and Arizona Revised Statutes, Section 13-3623 (a)(l ) and 705.

Count 2

On or about August 28,2011 in Grand Canyon, Arizona, Coconino County, within the confines of Grand Canyon National Park, an area within the special maritime and territorial jurisdiction of the United States, the defendant, Christopher Carlson, under circumstances likely to cause death or serious bodily injury, did knowingly cause the health of John Doe I (a twelve old male), a child who was under his care, custody and control, to be injured or placed in situation in which the health of John Doe) was endangered, in violation of Title ) 8 United States Code, Section 13 and Arizona Revised Statutes, Section 13-3623(a)(l) and 705.

Count 3

On or about August 15,2011 in Grand Canyon, Arizona, Coconino County, within the confines of Grand Canyon National Park, an area within the special maritime and territorial jurisdiction of the United States, the defendant, Christopher Carlson, under circumstances likely to cause death or serious bodily injury, did knowingly cause the health of John Doe 2 (a nine old male), a child who was under his care, custody and control, to be injured or placed in situation in which the health of John Doe 2 was endangered, in violation of Title 18 United States Code, Section 13 and Arizona Revised Statutes, Section 13-3623(a)(I) and 705.

Count 4

On or about August 28,20) I in Grand Canyon, Arizona, Coconino County, within the confines of Grand Canyon National Park, an area within the special maritime and territorial jurisdiction of the United States, the defendant, Christopher Carlson, under circumstances likely to cause death or serious bodily injury, did knowingly cause the health of John Doe 2 (a nine old male), a child who was under his care, custody and control, to be injured or placed in situation in which the health of John Doe 2 was endangered, in violation of Title 18 United States Code, Section 13 and Arizona Revised Statutes, Section \3-3623(a)(I) and 705.

Case 3:11-mj-04243-MEA Document 1 Filed 08/30/11 Page 1 of 24

CountS

On or about August 15, 2011 in Grand Canyon, Arizona, Coconino County, within the confines of Grand Canyon National Park, an area within the special maritime and territorial jurisdiction of the United States, the defendant, Christopher Carlson, under circumstances likely to cause death or serious bodily injury, did knowingly cause the health of John Doe 3 (an eight old male), a child who was under his care, custody and control, to be injured or placed in situation in which the health of John Doe 3 was endangered, in violation of Title IS United States Code, Section 13 and Arizona Revised Statutes, Section J3-3623(a)( I) and 705.

Count 6

On or about August 2S, 2011 in Grand Canyon, Arizona, Coconino County, within the confines of Grand Canyon National Park, an area within the special maritime and territorial jurisdiction of the United States, the defendant, Christopher Carlson, under circumstances likely to cause death or serious bodily injury, did knowingly cause the health of John Doe 3 (an eight old male), a child who was under his care, custody and control, to be injured or placed in situation in which the health of John Doe 3 was endangered, in violation of Title IS United States Code, Section 13 and Arizona Revised Statutes, Section 13-3623(a)( I) and 705.

I further state that I am a U.S. National Park Service Special Agent and that this complaint is based on the following facts:

See attached AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT (Statement of Probable Cause).

AUTHORIZED BY: AUSA Camille Bibles :& Continued on the attached sheet and made a part hereo~o

Christopher A. Smith. NPS Special Agent Name & Title of Complainant Signature of omplainant

Sworn to before me and subscribed in my presence,

~8~-~3~~=-~_1~/~________ at ______________~F~la~g~st=a~ff~,~A~r~iz~o~na~____ Date City and State

Mark E. Aspey, United States Magistrate Judge Name & Title of Judicial Officer Signature of Judicial offiCe7


IN THE UNITED STATES DISTRICT COURT FOR THE

DISTRICT OF ARIZONA

REDACTED AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

I, Christopher A. Smith, being duly sworn state the following:

1. I am a Special Agent (SA) with the National Park Service (NPS), United States Department

of the Interior. I am presently assigned to the Central Region, duty stationed at Grand

Canyon National Park. I have been employed by the NPS as a Special Agent since June

2004. From May 2002 until June 2004 I was a Special Agent with the Environmental

Protection Agency Criminal Investigation Division. Prior to this I was a Law Enforcement

Park Ranger with the NPS in Arizona and Maine. I have received specialized training at the

Federal Law Enforcement Training Center, completing the Criminal Investigator Training

Program and the Environmental Investigations Basic Training Program. I have attended

numerous advanced training courses in a variety of law enforcement subjects and have

conducted criminal investigations into a variety of offences.

2. The facts and information contained in this affidavit are based upon my personal knowledge

of the investigation and information provided to me by Law Enforcement Rangers Ken

Phillips, Rick Blair, Elizabeth Aurnou, Erika Anderson; Preventative Search and Rescue

(PSAR) Ranger Megan Smith; and observations of Susann Clinton who is a Registered Nurse

eRN) and a Family Nurse Practitioner (FNP-C). This affidavit contains information

necessary to support probable cause and it is not intended to include each and every fact or

occurrence in the matter observed by me or known to the Government.

3. The following excerpts are from the "Preventative Search and Rescue Program, History and


Function at Grand Canyon National Park":

"The Grand Canyon National Park is a destination for thousands of people each year.

Every summer hundreds of people venture below the rim to explore the depths of the

canyon. During the summers of 1995-96, park personnel responded to hundreds of

heat related incidents, some of which resulted in preventable deaths.

Take for instance these cases from Over the Edge: Death in Grand Canyon, by

Ghiglieri and Myers, 2001. "Miloslav Hanacek, a Czech national, who hiked down

the Bright Angel to Plateau Point. The inner canyon temperature was 111 degrees.

Miloslav was 66 and on his return hike to the rim, he suffered cardiac arrest brought

on by heat stroke. He died on June 10, 1995".

"Then there was Phillip Grim." Phillip Joseph Grim was 1 0 years old when he hiked

to the bottom of the canyon on the South Kaibab trail. Phillip hiked down ahead of

his uncle who was carrying all the water. Phillip died of heat stroke on July 23, 1996.

The shade temperature at the bottom that day was 116 degrees".

"Due to the increase of fatalities caused by heat related illness, the park's

administration decided to create a program that would educate the public about the

hazards of hiking at the canyon and how to mitigate them. This was the basis for

creating the Preventative Search and Rescue Program (PSAR)."

4. In addition to the PSAR program, Grand Canyon National Park, instituted a daily

assignment called "SAR Shift". Grand Canyon National Park has the busiest search and

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rescue (SAR) program in the National Park Service. This is due in large part to the volume

of incidents that occur on the Bright Angel Trail, which extends nine miles from the South

Rim down to the Colorado River. During 2010 Grand Canyon National Park emergency

personnel handled 286 search and rescue missions. 75% of these incidents occurred on the

Bright Angel Trail, including Indian Garden and Phantom Ranch. August is the busiest

month for search and rescue activities and heat is the leading contributing factor to these

incidents. For further information see Attachment A, prepared by Ken Philips, SAR

Coordinator, Grand Canyon National Park.

5. At approximately 5 :00 pm on approximately August 15, 2011, Law Enforcement Ranger

Aurnou was on patrol at the Indian Gardens area along the Bright Angel Trail within Grand

Canyon National Park. The high temperature for the day exceeded 100 degrees. Ranger

Aurnou contacted a male, later identified as Christopher Carlson, with his three juvenile

grandsons in the day-use area at Indian Gardens. The grandsons were identified as 12 year

old John Doe 1, 9 year old John Doe 2, and 8 year old John Doe 3 .

6. Other visitors had been telling Ranger Aurnou about Carlson and his party throughout the

afternoon because they were concerned for the boys because they looked exhausted. Ranger

Aurnou learned the group had already hiked from the South Rim to Plateau Point and back to

Indian Gardens, a distance ofapproximately 7.5 miles, and the boys all looked exhausted and

overheated. They were shirtless and slumped on the benches in the day use area. One of the

boys had his head back and his eyes closed. Carlson was rushing the boys to drink and go to

the bathroom quickly.

7. When Ranger Aurnou spoke with Carlson about the group's condition and plan he said they

were all fine in a defiant manner. Because Ranger Aurnou was concerned about the boys

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overheating she showed them how to get soaking wet in the water fountain to cool off.

Carlson told her they were all fine and didn't need to get wet. Ranger Aurnou offered them

food which Carlson declined for the group.

8. When Ranger Aurnou asked about their further hiking plans Carlson asked how far it was to

the Colorado River. Ranger Aurnou and Carlson then engaged in a discussion in which

Carlson was adamant he was going to hike to the river and then back to the rim with the

children. Ranger Aurnou explained it was too far, too late to start that long of a hike, and the

boys looked way too tired. Carlson persisted. When John Doe 1 went to the bathroom,

Carlson went to check on him.

9. While Carlson was gone, Ranger Aurnou asked the two younger boys how they were doing,

and they said they were tired and their legs hurt, and they didn't want to hike to the river.

She asked them about what they had eaten and drank during their hike, and they said they

had eaten some hummus. She asked them if they'd like some snacks and they said they

weren't allowed to eat anything but health food. Carlson returned and told her they were

going to get going to the river soon. He then approached Ranger Aurnou aggressively to

which she responded by moving back in equal measure. She was concerned Carlson may try

to assault her.

10. Ranger Aurnou advised Carlson he was not going to the river with the children: she wouldn't

allow it; it wasn't an option. She advised him the boys were tired, and it was getting late, and

if they went to the river and made it back out to the South Rim, they wouldn't be off the trail

until after midnight. He said that sounded fine to him.

11. Ranger Aurnou told Carlson it would be child endangerment if he forced the boys to go to

the river and back up to the South Rim and she would not allow him to go. He asked ifhe

4


could go if he left the boys at Indian Garden. Ranger Aurnou told him he could not abandon

his grandchildren at Indian Gardens and that he had two options: they could stay at Indian

Gardens for the night if they were too tired to hike out, or they could hike up the trail. He

told her he had paid his entrance fee and now he wasn't going to get his money's worth.

12. Carlson ultimately headed up the trail with his grandsons.

13. National Park Service employee Pat Bernardi, observed the interaction between Ranger

Aurnou and Carlson. After the four left, Benardi told Ranger Aurnou he was worried for the

boys' safety and thought the grandfather seemed abusive.

14. Ranger Aurnou radioed the Preventative Search and Rescue Ranger at 3 Mile Rest House

and asked him to check on the children's welfare and make sure they got a snack at the rest

house, and not to confront the grandfather in any way, as he seemed like he could be

dangerous.

15. Ranger Aurnou then contacted Ranger Justin Cully and asked him to keep a look-out for the

group on the South Rim and to check the welfare of the children.

16. On August 28, 2011, Ranger Erika Anderson was patrolling the Indian Gardens area of the

Bright Angel Trail when she contacted Carlson and the three boys. After the contact she

called Ranger Aurnou who was the SAR Shift and relayed she was concerned for the safety

of the children. Ranger Anderson went on to state Carlson was intimidating, controlling, and

would not allow her to speak to the boys about their hike or how they were physically

feeling. The boys looked exhausted. She was concerned for the boys safety but based on

Carlson's intimidating demeanor towards her and the boys she felt the safest thing to do was

to have law enforcement rangers contact them in a more controlled environment.

17. Shortly after the call from Ranger Anderson, Grand Canyon Regional Communication Center

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received a call from the emergency phone at the Three Mile Rest House. The caller was a

hiker on the trail who was reporting an adult white male with three African American

children who passed by at a very fast pace. The children were hyperventilation and one on

the children told the caller "call the agency" or "call the emergency". The description given

by the caller matched Carlson and the boys.

18. Shortly after the call from the emergency phone, PSAR Ranger Megan Smith passed Carlson

and the boys. Ranger Smith heard Carlson threaten the boys if they did not continue the pace

he would make them hike twice as hard. The youngest boy, later identified as John Doe 3 ,

was crymg.

19. These incidents were relayed to Law Enforcement Rick Blair, who responded to a position

along the rim where he could view portions of the Bright Angel Trail with binoculars.

Ranger Blair located Carlson and the three boys approximately % of a mile from the top of

the trail. Ranger Blair was able to observe the group travel for approximately 12 mile.

During that time he saw Carlson walking at a brisk pace, with a boy, later identified as John

Doe 1, walking in front of him. While Ranger Blair was observing the group, he saw Carlson

shove John Doe 1 thirteen times. Of those thirteen times, four appeared to occur when the

boy tried to stop and rest. Ranger Blair also witnessed Carlson whip John Doe 1 with a rolled

up tee shirt. When John Doe 1 was struck with the shirt he lurched forward.

20. Rangers contacted the group at the trail head and separated the boys from Carlson. Rangers

elected to make this contact at the trailhead as opposed to on the trail for fear a physical

confrontation make ensue with Carlson and the rangers did not want to risk that occurring on

a narrow trail alongside a cliff with three children present.

21. Once contacted, the boys were initially reluctant to speak but then began to relay the day's

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events including multiple instances of physical abuse against them by Carlson. The boys told

Ranger Aumou of being hit, pushed, choked, kicked, pinched, squeezed, and whipped. They

said they were not allowed to drink water on the hike down and resorted to drinking water

from the Colorado River. All three threw up on the hike mUltiple times. Overall, all three

relayed to Ranger Aumou they were afraid of Carlson, did not want to be placed back in his

care, and felt he should be arrested.

22. John Doe 2and John Doe 1 both relayed to Ranger Aumou that Carlson told them they had to

look happy when they passed other hikers, and they had to say they were "fine" when people

asked.

23. Rangers provided shelter and food for the boys in the park ambulance. While there the boys

ate four or five meals ready to eat (MRE), candy, chips, and fluids.

24. The hike completed by Carlson and the boys was approximately 19 miles long and on August

28,2011, the temperature at Phantom Ranch reached 108 degrees Fahrenheit. That same day

an adult died within Grand Canyon on the Tanner Trail. According to the Coconino County

Medical Examiner the cause of death was hyperthermia and dehydration due to

environmental heat exposure.

25. Carlson was ultimately arrested and the boys were placed in the care of Arizona Child

Protective Services.

26. On August 29,2011, all three boys were seen at The Safe Child Center, an accredited child

advocacy center, where they underwent forensic interviews and forensic medical exams.

During the interviews all three boys disclosed chronic physical abuse by Carlson. During the

forensic medical exam all three boys showed physical evidence of ongoing abuse including

injuries sustained at different times with different levels of healing. These injuries occurred

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over the course of the summer in various states within the United States as well in Mexico,

Jamaica, and countries in Central America. With regard to abuse within Grand Canyon

National Park, the boys were able to describe incidents which occurred on both trips to the

park, one on or about August 14 and 15,2011, and one on August 28,2011, when Carlson

was ultimately arrested.

27. On August 29, 2011, your affiant observed a forensic interview of John Doe 1 at the Safe

Child Center in Flagstaff, Arizona. John Doe 1told the interviewer "Chris was beating us."

28. During the exams at Safe Child, he went on to describe the following events taking place on

the August 28,2011, trip to Grand Canyon National Park. All of these events took place

between the South Rim and Phantom Ranch, along the Bright Angel Trail corridor.

According to John Doe 1, the group left the South Rim at approximately 7:00 am, hiked to

Phantom Ranch, and then returned to the South Rim at sunset.

a. During the hike he and his brothers were not allowed to drink any water until Carlson

said they could and the boys had no water until they reached Phantom Ranch. When

they would ask Carlson for some water he would say no, then he would drink some

water himself in front of the boys. Carlson drank so much of the water he had to

refill the bottle. The boys were able to sneak two drinks of water, one when they

were down at the Colorado River and Carlson said they could dunk their heads in the

water to cool off so John Doe 1 was able to sneak a drink of river water, and once

when Carlson had to use the restroom at Indian Gardens on their return trip. When he

went to the restroom John Doe 1 was able to sneak a drink from the water fountain.

b. When Carlson finally did give him and his brothers some water they threw it up after

drinking it. Carlson then told them they would not get any more water until they got

8


to top of the trail. He threw up three times on the hike, John Doe 2 threw up twice,

and John Doe 3 threw up five or six times.

c. As a result of not drinking, his lips were dry and cracked. As a result of his mouth

being so dry, when Carlson did give him some food he could not chew it quickly.

Carlson became angry at this and grabbed him by his jaw, digging his finger into both

sides of his cheeks.

d. During the hike he was repeatedly hit with an open hand and pushed down to the

ground by Carlson. He has a bruise on his arm from being pushed down.

e. While hiking Carlson grabbed him hard by the back of neck and called him a "mother

fucker." Carlson would also dig his fingers into his shoulder in a pressure point

manner.

f. Carlson kicked him multiple times in the butt which hurt. Carlson was wearing steel

toed boots.

g. Carlson told John Doe 2 to hide his wounds on his feet from the rangers.

h. While hiking up the trail he kept falling because his legs were cramping and they

would give out. This would anger Carlson who would then choke him and pick him

up by his throat. Sometimes Carlson would pick him up by the throat and then throw

him to the ground. He has scrapes on his legs from this happening.

I. John Doe 1 was so exhausted, when they came to a rest area he would tell Carlson he

needed to use the restroom just so he could rest for a few minutes. When he really

did need to go the bathroom on the trail, Carlson would only allow the boys three

minutes to defecate. When he went to go into one of the outhouses at the Three Mile

Rest House along the trail, Carlson followed him in, pulled his shorts down, hit him

9


in the back of head, pushed him into wall of the outhouse while choking him. He

then struck him again.

J. John Doe 1 asked other hikers to call 911 and to get help for him and his brothers

from Carlson's beatings. He did this secretively because if Carlson found out he had

told them he would have been beaten.

k. When he wasn't hiking fast enough, Carlson took John Doe 1 's tee shirt, which he

had soaked in water to try and stay cool, and whip him in the back with it. The

whi pping hurt.

I. As they continued on he felt worse. His head started to feel like it was going to shut

down; like when you have been in a hot tub too long. He began to see two of things

and when he told Carlson about this Carlson told him it was "trail vision". Then his

eyes started to close and the sound started to get quitter. John Doe 1 described the

sound getting quieter like in a baseball movie when the fans get really quiet during a

scene.

29. According to Susann Clinton who is a Registered Nurse (RN) and a Family Nurse

Practitioner (FNP-C), the above symptoms described by John Doe 1 are indicative of heat

stroke. Heat stroke is a very serious medical condition that can be lethal.

30. During the exams at Safe Child, John Doe 1 also described their first trip to Grand

Canyon National Park on or about August 15, 2011. On this trip they hiked between the

South Rim and Plateau Point, along the Bright Angel Trail corridor. Carlson wanted to go to

the river then but they were stopped by a ranger. During this hike the following happened to

him:

a. Carlson pushed him down onto a rock and then kicked him. He had a big bruise on

10


his leg as a result.

b. Carlson pushed him down onto a rock, kicked him, and smacked his face down onto

the rock. As a result his leg was cut, lips were bleeding, and his nose was scratched.

When they approached Indian Gardens Carlson told him to wipe his lips so the ranger

wouldn't see the blood.

c. Carlson also pushed him into a plant and he got needles stuck in his hand.

d. Carlson repeatedly hit him in the face with an open hand.

e. Carlson threw a rock at him and hit him in the leg.

f. Carlson called him a "fat ass".

31. John Doe 1 also described how Carlson would not allow them to wear underwear. He would

also make them take off their shirts and drive with the windows rolled down with the cold air

blowing on them if they began to fall asleep while he was driving. If they were staying in a

hotel, Carlson would require them to use the restroom with the door open. John Doe 1

described many other incidents of assault taking place in areas outside of Grand Canyon

National Park.

32. On August 29,2011, RNI FNP-C Susann Clinton conducted a forensic medical exam of John

Doe lat the Safe Child Center. RN/FNP-C Clinton found the following injuries:

a. a laceration on his left leg which he stated occurred when Carlson pushed him down

on the Bright Angel Trail while hiking during their first trip to Grand Canyon on

approximately August 15,2011;

b. an injury to his lower lip, due to dehydration, dry mucus membranes, and lack of skin

barrier lip protection while hiking in Grand Canyon,

c. a dark pink raised scar on his right cheek which he stated was from a cut he received

11


when Carlson struck him with his hand while holding a set of keys in Mexico,

d. lacerations on his left foot and ankle area which he stated he sustained when Carlson

forced him to hike barefoot in Santa Barbara,

e. a small laceration on his neck which may have been sustained one of the times

Carlson choked him while they were hiking,

f. a bruise on his left upper arm he stated he sustained when Carlson pushed him down

while they were hiking the second time in Grand Canyon,

g. abrasions on his left leg which he stated he sustained when Carlson pushed him down

on the trail at Grand Canyon on August 28,2011,

h. A faint yellow dark brown bruise with an underlying palatable firm mass residual of

deep tissue injury and inflammation on his upper left leg where he stated he sustained

a contusion when Carlson pushed him down and kicked him striking his left leg onto

a rock during their first trip to Grand Canyon.

I. Sever groin chaffing with some open sores as a result of the excessive hiking without

skin barrier protection to manage moisture and friction.

33. On August 29,2011, your affiant observed a forensic interview of John Doe 2 at the Safe

Child Center in Flagstaff, Arizona. During the exams at Safe Child, he went on to describe

the following events taking place on the August 28, 2011, trip to Grand Canyon National

Park. The following events took place between the South Rim and Phantom Ranch, along

the Bright Angel Trail corridor.

a. He and his brothers did not get to eat any breakfast before hiking and were only

allowed to eat celery on the hike down.

b. He and his brothers were not allowed to drink any water until they got to the river. He

12


was very thirsty and his lips were dry. A woman hiking by offered him water but he

was afraid Carlson would catch him drinking the water. Other hikers kept offing him

and his brothers water but Carlson said no. On the way up he only got a little water to

drink.

c. He threw up multiple times on the hike and his brothers also threw up. Carlson also

made him and his brothers stick their fingers down their throats to make themselves

throw up.

d. Carlson made him hike with blisters he still had from the last hiking trip from the

Grand Canyon. His blisters were getting worse and worse on the second hike. He

told Carlson about his blisters on the hike and asked for breaks but Carlson said no.

e. Carlson got mad at him and "pushed his head" and then made him run up the trail.

f. He got hurt by Carlson. Carlson pushed him on his back, grabbed him by the neck,

made him run, and elbowed him in the face.

g. On the hike his toes were cramping and hurting. Carlson made him continue hiking

and run in sections.

h. It looked like John Doe 1 was drunk when he was hiking up the traiL His legs kept

cramping.

I. Carlson told John Doe I he had to walk on the side of the trail by the cliff. He was

scared John Doe 1 was going to fall over the cliff because his legs were cramping and

he was dizzy. Carlson told John Doe 1 he was going to fall over the edge. He was

afraid for John Doe 1.

J. Carlson was hurting him and his brothers.

k. He kept asking Carlson for a break but he wouldn't give them one. He was afraid he

13


or his brothers were going to pass out.

l. Carlson told him and his brothers to hurry up while hiking out and told them if

because of them he missed seeing the Grand Canyon during the daylight hours on

their drive out he was going to hurt them badly. He and his brothers were really

scared.

m. Carlson told them not to tell the rangers anything about what happened and told him

and his brothers they better have smile on face when they pass people, act happy, and

say "Hi".

n. It was good John Doe 1 got someone to call the rangers.

34. John Doe 2 also described the following events taking place during their first trip

into the Grand Canyon on the August 15, 2011.

a. During this hike Carlson would not give him much water even though he was

sweating profusely.

b. "Ranger Betsy" saved him and his brothers from having to hike down to the river.

She would not let Carlson take them to the river.

c. Carlson made John Doe 2 and his brother's walk fast up the trail because he was mad

the ranger wouldn't let them hike to the river.

35. John Doe 2 also told the interviewer they are only allowed to sleep when Carlson sleeps. He

has made them stay up until 4:00 in the morning before. If they start to fall asleep while

driving, Carlson makes them take their shirts off and rolls the windows down so the cold air

blows on them. They are not allowed to wear underwear.

36. His mom told Carlson that the boys "better be getting air" ifhe is choking them.

37. John Doe 2 described many other incidents of assault taking place in areas outside of Grand

14


Canyon National Park. During one of these incidents Carlson grabbed his scrotum and penis

and squeezed them hard. Carlson did this to him as punishment for John Doe 2 accidently

defecating in his pants.

38. On August 29, 2011, RNI FNP-C Susann Clinton conducted a forensic medical exam of John

Doe 2 at the Safe Child Center. RNIFNP-C Clinton found blisters that had become ulcers on

John Doe 2's feet and ankle area as well as more normal blisters. According to John Doe 2,

he sustained these blisters during both hikes into the Grand Canyon. At least one of the

blisters that turned into an ulcer occurred during the first trip to Grand Canyon.

39. The ulcers will require follow up examination by medical personnel to evaluate for proper

wound care and infection. These ulcers may require antibiotics.

40. On August 29, 2011, your affiant observed a forensic interview of John Doe 3 at the Safe

Child Center in Flagstaff, Arizona. During the exams at Safe Child, he went on to describe

the following events taking place on the August 28, 2011, trip to Grand Canyon National

Park. All of these events took place between the South Rim and Phantom Ranch, along the

Bright Angel Trail corridor.

a. Carlson whipped him with a tee shirt multiple times and it hurt.

b. Carlson choked him and threw him on the ground multiple times. The choking felt

like a snake around his neck.

c. Carlson used "pressure points" on his neck.

d. Carlson hit him in the head with an open hand which hurt, and repeatedly kicked him

with his hiking boots

e. Carlson yelled at him repeatedly and called him a "mother fucker."

f. Carlson would not allow him to drink any water on the hike down.

15


41. John Doe 3 went on to describe how he cried during the trip. Carlson would often hurt him

when he was unable to hike fast enough or when he asked Carlson for water. The morning of

the hike he and his brothers did not get any breakfast.

42. During the exams at Safe Child, John Doe 3 also described their first trip to Grand Canyon

National Park on or about August 15, 2011. On this trip they hiked between the South Rim

and Plateau Point, along the Bright Angel Trail corridor. During this trip the following

happened to him:

a. Carlson repeatedly hit and kicked him.

b. The night before they hiked, while on the rim, he became scared after seeing where

they were supposed to hike. He began to cry. Carlson got mad at him for crying and

began hitting John Doe 3 in the face and head multiple times, Carlson was yelling at

him while he was hitting him, His hitting made John Doe 3's nose bleed and he had

blood on his pants and shirt,

43. Sometimes Carlson makes them take off their shirts and he rolls the windows down in the

van and it is cold. This happened at least once while in Grand Canyon National Park.

Sometimes he spits water on them when they have no shirt on,

44. Carlson has told him if John Doe 3 and his brothers made things hard for him the boys will

get "beat down." John Doe 3 knows a "beat down" is punching and hitting.

45. John Doe 3 described many other incidents of assault taking place in areas outside of Grand

Canyon National Park.

46. On August 29, 2011, RNI FNP~C Susann Clinton conducted a forensic medical exam of John

Doe 3 at the Safe Child Center. RN/FNP~C Clinton found peeling skin and cracks on his lips

due to dry mucous membranes from lack of hydration, and lack of lip protection. John Doe 3

16


also had severe groin chaffing with scabbing as a result of excessive hiking without skin

barrier protection to manage moisture and friction.

47. All of the brothers independently stated they observed Carlson physically abuse each other.

48. According to RNI FNP-C Susann Clinton, all of the boys displayed symptoms of dehydration

and heat exhaustion. John Doe 1 also had some symptoms of heat stroke. Heat stroke is a

very serious medical condition that can be lethal.

49. On August 28, 2011, your affiant interviewed Carlson. Carlson denied any physical abuse

against the children.

50. Based upon the facts as stated in this affidavit, your affiant respectfully submits that there is

probable cause to believe:

a. On or about August 15,2011 in Grand Canyon, Arizona, Coconino County, within

the confines of Grand Canyon National Park, an area within the special maritime and

territorial jurisdiction of the United States, the defendant, Christopher Carlson, under

circumstances likely to cause death or serious bodily injury, did knowingly cause the

health of John Doe 1 (a twelve old male), a child who was under his care, custody and

control, to be injured or placed in situation in which the health of John Doe 1 was

endangered, in violation of Title 18 United States Code, Section 13 and Arizona

Revised Statutes, Section 13-3623(a)(1) and 705.

b. On or about August 28, 2011 in Grand Canyon, Arizona, Coconino County, within




health of John Doe 1 (a twelve old male), a child who was under his care, custody and

17





c. On or about August 15,2011 in Grand Canyon, Arizona, Coconino County, within




health of John Doe 2 (a nine old male), a child who was under his care, custody and



Revised Statutes, Section 13-3623(a)(l) and 705.

d. On or about August 28, 2011 in Grand Canyon, Arizona, Coconino County, within




health of John Doe 2 (a nine old male), a child who was under his care, custody and




e. On or about August 15,2011 in Grand Canyon, Arizona, Coconino County, within




18


health of John Doe 3 (an eight old male), a child who was under his care, custody

and control, to be injured or placed in situation in which the health of John Doe 3

was endangered, in violation of Title 18 United States Code, Section 13 and Arizona


f. On or about August 28,2011 in Grand Canyon, Arizona, Coconino County, within




health of John Doe 3 (an eight old male), a child who was under his care, custody

and control, to be injured or placed in situation in which the health of John Doe 3

was endangered, in violation of Title 18 United States Code, Section 13 and Arizona


I declare under penalty of perjury the information set forth above in this affidavit is true and correct to the best of my knowledge and belief.

c~ Special Agent National Park Service Department of the Interior

Sworn to and subscribed before me this 3ll fay of August, 2011

United States Magistrate. udge The Honorable Mark J. pey

19


Appendix A


Grand Canyon National Park has the busiest search and rescue program in the National Park Service. This is due in large part to the volume of incidents that occur on the Bright Angel Trail, which extends nine miles from the South Rim down to the Colorado River. During 2010 Grand Canyon National Park emergency personnel handled 286 search and rescue missions. 75% of these incidents occurred on the Bright Angel Trail, including Indian Garden and Phantom Ranch. Based upon the assessment of involved patients, EMS providers treated 148 heat related injuries.

During the early 1990's, Grand Canyon National Park experienced record high summertime temperatures in conjunction with record-breaking visitation. Park emergency personnel were overwhelmed by the volume of hikers in distress, particularly on the Bright Angel Trail, with heat-related injuries as well as fatal accidents. The preventative search and rescue (PSAR) was developed to improve hiker education and decrease related injuries. The PSAR program was initiated in 1997 HIKE· SMART program with improved messaging. A PSAR Supervisor plus 'five seasonal rangers conduct PSAR efforts on a daily basis from May through September. Included PSAR trail patrols on Bright Angel and South Kaibab Trails, which resulted in 224 "hiker assists." Without the physical intervention of PSAR personnel on these incidents, the situation would have evolved into a medical emergency.

The list below reflects the tremendous volume of annual incidents that occur on the Bright Angel Trail.

EMS Incident Location (Canyon Trails): Bright Angel Trail South Kaibab Trail North Kaibab Trail Backcountry Trails

216 21 25 13

Year NPS Helicopter SAR Medevac

Transports

Cardiac Arrest

Heat-Related Injuries

SAR Related Fatalities

2010 157 5 148 9

SUBJECT ACTIVITY- FATALITY· (9) Hiking, Day - 5 Suicide- 3 Other- 1


CONTRIBUTING FACTOR, SUBJECT (Note: Incidents may include more than one contributing factor) Fatigue/Physical Condition 106 Insufficient Information/Error in Judgment 74 Weather, Heat 148

2010 SAR INCIDENTS BY MONTH (286 TOTAL)

60 51

50

40

30

20

10

o

The Bright Angel Trail exposes unwary hikers throughout the summer to heat-related illness, including heat exhaustion. hyponatremia and life-threatening heat stroke. The majority of hikers who become injured or must be rescued are day hikers. Day hikers are physically less prepared than overnight hikers with the proper amount of equipment and physical conditioning. Additionally day hikers spend less time planning for a safe hike within their abilities. They repeatedly make their plans on the spur of the moment with a goal of hiking to the a set destination (e.g. Colorado River and back to the rim) without regard for the physical abilities of all members of their group. The daily summer inner canyon temperatures can exceed 110 degrees at Phantom Ranch, which places every ill-prepared or unwary hiker in potential jeopardy. These circumstances result in hikers becoming distressed in the afternoon, while attempting to hike out of the canyon, and requiring assistance from NPS rescue personnel.

Prepared By Ken Phillips. Chief Emergency Services Grand Canyon National Park

August 30,2011

JAN FEB MAR APR MAY JUN JULAUG SEP OCT NOV DEC


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