STATE OF MARYLAND

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IN THE CIRCUIT COURT
VS.
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ROBERT RICHARDSON III
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CASE NO. 12-K-12-291
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AGREED STATEMENT OF FACTS
The State and Defense stipulate to the following statement of facts:
On January 9, 2012, at approximately 10:30 p.m., deputies from the Harford County
Sheriffs Office responded to a call to check on the welfare of a Robert Richardson, Jr., who
resided at 831 Moore's Mill Road in Bel Air, Maryland, in Harford County. The call was in
response to a call made to the 911 center by family members of Mr. Richardson who were
concerned about a telephone call that had been received by Abigail Richardson from the
defendant, who is her brother. The defendant told her that he had shot their father, who would be
identitied as Robert Richardson Jr. Deputy Christopher Jordan arrived at the house, located at
831 Moores Mill Road, Bel Air, Harford County, Maryland, at approximately I 0:45p.m.
Deputy Jordan was familiar with the location, and noticed that the main vehicle that was used by
the resident was not parked in the driveway. He also noticed that there were lights on in the
house. He observed what he determined were fresh tire tracks in the front yard leading to the
front stoop, and saw what he believed to be fresh blood on the main stoop. He knocked on the
door and there was no response. He shone his tlashlight through the front window of the house,
later determined to be the bedroom of the victim, Robert Richardson, Jr., and saw what appeared
to be blood on the bed. He looked through another window to the living room, and also saw
what appeared to be blood and drag marks. When other officers arrived, they forced entry into
the house and conducted a quick search of the house, looking for Mr. Richardson. They were
unable to locate anyone in the house, but did see what appeared to be blood in the front bedroom,
and drag marks and a blood trail leading from the bedroom to the front door of the house. The
police exited the house and secured it pending a search warrant.
A check of the records of the Maryland Motor Vehicle Administration determined that
the victim, Robert Richardson, Jr., owned an older model Chevy S 10 Blazer, with tag no.
53464M5. Deputies also checked local hospitals for Mr. Richardson, with negative results. A
lookout was placed for the Chevy Blazer. A search and seizure warrant was also obtained for the
Chevy Blazer.
Deputy Wil Adams of the Harford County Sheriffs Office went to interview the
defendant's sister, Abigail Richardson. Ms. Richardson advised that the initial call had come
from her brother, who she would identify as the defendant, Robert Richardson III. At his
request, Abigail called her brother on the cell phone from which he had placed the call to her.
He answered but would not divulge his location. Dep. Adams then took the phone but the
defendant hung up the phone and would not answer further attempts to contact him. Abigail
further told the Deputy that the defendant had told her that he shot his father in the bedroom at
the Moores Mill Road address and was going to get rid of the body. Detectives began attempts
to locate the phone by sending "pinging" or sending locating signals to the phone, and later
recovered it on the ground in the area of the 1300 block of Thomas Run Road in Churchville,
Maryland.
In the early morning hours of January 10, 2012, at approximately 6:00a.m., Trooper
Justin Gross of the Maryland State Police was on his way to work, at the Bel Air Barracks in Bel
Air. He heard the radio chatter with the lookout for the Chevy Blazer, and heard the dispatcher
direct all available units to the area of Jarrettsville Road and Baldwin Mill Road in Jarrettsville,
Maryland, where the vehicle had been spotted. Since he was already in the area, he began
looking for the vehicle. He spotted it travelling on Jarrettsville Road and began following it, but
did not initially make an attempt to stop it, because he was waiting for back up to arrive. When
the vehicle was stopped for a light at the intersection of Rt. 24 and Jarrettsville Road, he
determined that it was occupied and being operated by one white male. They proceeded
eastbound on Jarrettsville Road. The Blazer then turned right onto Conowingo Road, headed
towards Bel Air. Other marked MSP cruisers began to set up around the Blazer, and the suspect
immediately accelerated the Blazer. Troopers activated their lights and sirens and began the
pursuit. The Blazer drove at a high rate of speed, passed through several red lights, continued
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onto Hickory A venue, through the town of Bel Air, continued toward Churchville Road, onto
Fulford Avenue towards Linwood Avenue. As he was turning into the parking lot of the Bel Air
United Methodist Church, he lost control of the vehicle and crashed it into a metal pipe sticking
out of the ground, and into a cinder block structure. The vehicle came to a stop, and the driver
ran a short distance and stopped. He was apprehended and would be identified as the defendant,
Robert Richardson III.
The defendant was placed under arrest and was transported by Det. Nick Petrozzino of
the Harford County Sheriff's Office to the Criminal Investigations Division of the Sheriff's
Office. Prior to transport, he was advised of his Miranda Rights by Det. Petrozzino. The
defendant waived his rights. He was asked where he put his father's body, and he told the
Detective that he had put it at 828 Gilbert Road, Aberdeen, Maryland, and gave directions to
where he put the body, directing the officers to a pond on that property. Deputies responded to
the Gilbert Road address and located the body of the victim, Robert Richardson, Jr., on the edge
of the pond. He had been wrapped in a bed spread but was lying in the water. The body was
recovered and was taken to the Office of the Chief Medical Examiner in Baltimore. An autopsy
was performed by Dr. Ali, who is an Assistant Medical Examiner, and an expert in forensic
pathology. His report and his testimony would be that the victim died as a result of a single
gunshot wound to the head. The entry point of the bullet was the back of the head. The bullet
travelled through the head and exited through the victim's forehead. His opinion, to a reasonable
degree of medical certainty, is that the cause of death was the gunshot wound to the head, and the
manner of death was homicide. It was not a close range shot. (See autopsy report, attached as
Exhibit 1).
The defendant was taken to the Criminal Investigations Division of the Harford County
Sheriffs Office located in Forest Hill, Maryland. He was advised of his Miranda rights by Det.
Andrew Lane of the Harford County Sheriff's Office. He waived his rights and agreed to give a
statement. The defendant advised the detectives that he was tired of the way that his father
treated him. He was done with it, and he shot his father in the back of the head with a .38
revolver. He said that his father was lying in bed with his back to him, watching television. The
defendant stated that after he shot his father, he left the residence and drove around in the truck,
then came back and wrapped the body in a blanket, put him in the back of the Blazer, and
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dumped the body into the pond at Gilbert Road. He drove around, drove into Pennsylvania then
drove back into Maryland where he was later involved in the pursuit and was apprehended. He
advised that the gun was located in the console of the Blazer. He advised that he had decided a
few weeks before that he had had enough of his father. It took him awhile to actually do the
shooting. He stated that his father was verbally abusive, over temperamental, and threatened him
verbally and physically. He stated that his father used to beat him but he started fighting back as
he got older. He stated that his father still hit him occasionally. He stated that his father treated
him like he was his slave. He advised that he armed himself with the .38 revolver and was
looking for an opportunity to do it. He stated that that day, he had gone to school, came home,
and he and his father drove around the area for a while. They arrived back home at about 8:30
p.m. and the defendant got on the computer which was in his father's bedroom while his father
watched TV. The defendant had the gun in his possession, was messaging with his friend, later
identified as J.K. and decided to do the shooting then. He went into his bedroom, took a drink
from a bottle of rum that was in his room, and went back into his father's room and shot him. He
left, went for a drive, smoked some marijuana, came back, removed the body, changed his
clothes, called his sister, and drove around until the police caught him. He also admitted that he
received the call from his sister and the police officer on the cell phone, so he threw the phone
out of the window ofthe vehicle so it could not be traced.
A search warrant was conducted on the residence at 83 1 Moores Mill Road. The
detectives took samples of the carpeting throughout the residence that contained suspected blood.
They also recovered blood stained blankets and sheets from the master bedroom. They also
recovered a lead projectile from the tloor of the master bedroom, and recovered a white hooded
sweatshirt and blue jeans from the defendant's bedroom.
A search warrant was conducted of the Chevy Blazer. Detectives took blood swab
samples from the interior and exterior of the vehicle. They also recovered a Rossi .38 caliber
revolver that was fully loaded, two boxes of ammunition for the revolver from the center
console. They also recovered a receipt for the purchase of gasoline at a Wa Wa store from the
early hours of January 10,2012, and a receipt from a Rite Aid store for the purchase ofVisine
eye drops from the early hours of January 10, 2012. Detective Lane obtained a copy of
surveillance tapes from both places. The Rite Aid surveillance tape showed the defendant
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entering the store accompanied by another young white male. Detectives were able to determine
his identity as J. K., who attended school with the defendant and was his friend. J.K. was located
and was interviewed about his knowledge of the events of January 9-10, 2012. 1 .K. was 14 years
old. He told the detectives that he received a phone call from the defendant and another friend,
D.B. in the evening of January 9, 2012. He then was picked up by the defendant and D.B. in the
defendant's father's Blazer. The defendant told them that he had shot his father. They went to
the defendant's house. J.K. would state that he saw blood everywhere. He also saw the victim's
body in the house. He helped the defendant by gathering clothing and other personal items as the
defendant was going to run away. D.B. and the defendant removed the victim's body by
wrapping it in a blanket, dragging it through the house, and putting it in the back of the Blazer.
They then drove to the pond in Aberdeen. He stayed in the car while D.B. and the defendant
removed the body and pushed it into the pond. They then went to a location in Aberdeen where
they sat and smoked marijuana. They took D.B. home, and he and the defendant went to Rite
Aid to purchase some Visine so that J.K. could hide his marijuana use from his father. The
defendant then took him home. A search warrant was obtained for his residence and the police
recovered the clothing and shoes that he was wearing that night.
The detectives then contacted D.B., who was 16 years old. He told the detectives the
same events as did J.K., and admitted that he helped remove the victim's body and put it in the
pond. He would also testify that he was a close friend of the defendant and was aware that the
defendant's father was verbally and physically abusive towards him. A search warrant was
obtained for his residence and the police recovered the clothing and shoes that he was wearing
that night.
The revolver that was recovered from the vehicle was sent to the Maryland State Police
Ballistics Unit along with the projectile that was recovered from the bedroom of the house. The
items were examined by Mr. Tarin Zuber, who is employed as a firearms examiner. He
conducted testing on the revolver and determined and would testify that the revolver was an
operational tirearm. He would further testify that the projectile that was recovered from the floor
of the bedroom was shot using the Rossi revolver.
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Detectives obtained search warrants for the DNA samples of the defendant, and of D.B.
and J.K. These were sent to the DNA unit of the Maryland State Police Crime Lab along with
the samples of the victim's blood and the swabs recovered from the Blazer and the residence,
and the clothing worn by the defendant that was recovered from his room, and the clothing
recovered from D.B. The evidence was analyzed by Tiffany Keener, who is employed as a DNA
analyst by the Maryland State Police. She would testify as an expert witness in the area of
forensic serology and DNA analysis. Her examination of the evidence determined that the
victim's blood was found on the white sweatshirt that was recovered from the Defendant's
bedroom, the plaid shorts recovered from the defendant, the swab from the front door mat to the
residence, the swabs taken from the living room carpet of the residence, the swab taken trom the
master bedroom of the residence, and the swab taken from the front porch to the residence, and
the swab taken from the carpet in the rear of the Blazer.
The defendant would call Dr. Joanna Brandt, who is a forensic psychiatrist employed in
private practice and licensed to practice psychiatry in the State of Maryland. She conducted
evaluations ofthe defendant at the request ofthe defense on the following dates: 1/10112,
1120112, 12112112, and 2114/13. She would testify and would give the opinion, to a reasonable
degree of medical certainty that the defendant was suffering from post-traumatic stress disorder
and major depressive disorder, as well as cannabis use and alcohol use disorder. Her opinion is
that he suffered this as a result of the pervasive physical and emotional abuse perpetrated by his
father, who repeatedly threatened and attempted to kill him.
The defendant would also call Dr. Wade C. Myers, who is the director of Forensic
Psychiatry at Rhode Island Hospital. He would testify as an expert in the battered child
syndrome and would testify to a reasonable degree of medical certainty that the defendant was
suffering from Posttraumatic Stress Disorder as a result of repeated threats of death and serious
injury from physical and emotional abuse from his father. He would also testify that the
Defendant's actions were consistent with someone who was suffering from Battered Child
Syndrome. He would also testify that the defendant suffered from depressive disorder as a result
of the abuse from his father. He would also testify that the defendant suffered from substance
abuse disorder. He would testify that, in his opinion, based on his examination of the evidence
and the testimony that the defendant was responding to a reasonable, honestly perceived,
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imminent threat of death when he shot his father. This is based on the evidence of the pattern of
repeated physical and verbal abuse of the defendant by his father. This is further based on the
evidence of neglect from the father by failing to provide adequate food, clothing, and heat for the
defendant. The defendant lived in a nearly constant state of fear that his father would harm or
kill him. This escalated into the father earms to terrorize the defendant. He would
VIc ')t 7)'[r
testify that the way that the defeJttHt w not is common in instances where the homicide is
<t t/irr...'f:r-'
perpetrated by children who are Sttltering'fr'om battered child syndrome.
Respectfully Submitted,
Diane Adkins Tobin, Esq.
Deputy State's Attorney
for Harford County
20 West Courtland Street
Bel Air, MD 21014
410-638-3500
\
ay&ehlef;
Counsel for Defe dant
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