Manslaughter Charge Against Then-Deputy

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Margaret H.

Olson, #6296
Summit County Attorney
Patricia Cassell, 35928
Chief Prosecutor
Ivy Telles, #14498
Prosecutor
6300 Justice Center Road
Park City, Utah 84098
Telephone (435) 615-3828
[email protected]
[email protected]
[email protected]
Attorneys for Plaintiff
______________________________________________________________________________

IN THE FOURTH DISTRICT COURT


in and for UTAH COUNTY
STATE OF UTAH

THE STATE OF UTAH, INFORMATION

Plaintiff, Summons

vs. Case No.

JOSEPH RICHARDSON, Judge


D.O.B. May 29, 1969
LEA Case No. 21PG01613
Defendant.

The undersigned prosecutor states on information and belief that the defendant, either
directly or as a party, committed the crime(s) of:

1. MANSLAUGHTER, in violation of Utah Code 76-5-205, a second degree felony, as follows,


to wit:

That on or about March 16, 2021, in Summit County, State of Utah, the defendant, did (a)
recklessly cause the death of another; (b) intentionally, and with knowledge that another
individual intends to commit suicide or attempt to commit suicide, aids the other individual
to commit suicide; (c) commit a homicide which would be murder, but the offense was
reduced pursuant to Utah Code § 76-5-203(3); or (d) commit murder, but special mitigation
was established under Utah Code § 76-5-205.5.
This Information is supported by a Statement of Probable Cause as follows:

On March 16, 2021, at approximately 3:54 pm, Joseph RICHARDSON (dob


05-29-1969) was driving southbound in his black Toyota Tacoma on 900 East around 433 North
in Provo, Utah when he collided with a Toyota Avalon and killed J.S., the driver of the other
vehicle.

Crash data was obtained from both vehicles. According to the event data recorder from
RICHARDSON's Tacoma, the Tacoma's speed was 56.5 mph 4.7 seconds prior to the crash. The
data then shows that the Tacoma's speed rose to 57.8 mph 2.2 seconds prior to the crash. The
data then shows deceleration began at 1.7 seconds prior to the crash and decreased from 57.2
mph to 37.9 mph at the moment that the crash occurred. The posted speed limit in this area is 35
mph. Witness statements indicate that RICHARDSON's Tacoma was traveling at a high rate of
speed faster than the posted speed limit.

Video from Grifols Biomat shows RICHARDSON's Tacoma traveling southbound in


lane number two (the right-hand lane) and proceeding through a green light at 450 North 900
East prior to the collision. The timestamp from the Grifols video shows the collision occurred at
15:54:38. Video of the collision was also obtained from Little Caesar's Pizza and Taco Bell.

Immediately prior to the collision, the Avalon driven by, J.S., exited from the Taco Bell
drive-through and turned left onto 900 East to go northbound. The event recorder data from
RICHARDSON's Tacoma show that RICHARDSON applied his brakes and swerved to the left.
RICHARDSON's Tacoma collided with J.S.'s Avalon. The collision happened at the location of
433 North 900 East in the multi-use (turn) lane. Damage was observed to the front bumper
off-centered to the left side of RICHARDSON's Tacoma. Damage was also observed to the right
driver door and B pillar of the Avalon. RICHARDSON exited his vehicle and rendered aid to
J.S. However, paramedics later arrived on scene and pronounced the death of J.S. at 16:03:56.
The Medical Examiner's report lists J.S.'s immediate cause of death as blunt trauma of the head.

When asked by an officer on scene if he saw what happened, RICHARDSON pointed to


his truck and stated that he was the other driver. RICHARDSON mentioned that he was on his
way to the "7J event" for SWAT and said, "As I was coming down here I saw him start to pull
out in front of me. I shouldn't... I shouldn't have tried to beat him." Analysis of the event data
recorder from RICHARDSON's Tacoma supports his statement.

This information is based on evidence obtained from the following witnesses:

J. Motsinger
[The State reserves the right to supplement its
witness list as additional discovery warrants]

Authorized for presentment


and filing March 7, 2022.

MARGARET H. OLSON
Summit County Attorney

_____________________________
/s/ Patricia S. Cassell
Chief Prosecutor

DEFENDANT'S LAST KNOWN ADDRESS:

2130 North Temple View Drive


Provo, Utah 84604

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