UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TENNESSEE

AT CHATTANOOGA

UNITED STATES OF AMERICA )

) No. 1:19-cr-125
v. )
) Judge Mattice
DESMOND LADON LOGAN )

UNITED STATES’ SENTENCING MEMORANDUM

The United States of America, through the undersigned prosecutors, files this sentencing

memorandum and respectfully requests that this Court impose a sentence of at least 17 years in

prison for the multiple acts of sexual violence to which the defendant admitted guilt as part of the

plea agreement (Doc. 2). Such a sentence comports with the factors set forth in 18 U.S.C. §

3553, holds the defendant accountable for his egregious acts, vindicates the victims’

Constitutional rights, and accounts for the defendant’s early acceptance of responsibility.

I. INFORMATION AND GUILTY PLEA

On September 12, 2019, the defendant waived indictment and pleaded guilty to a

Superseding Information (Doc. 1) charging him with two violations of 18 U.S.C. § 242

(Deprivation of Constitutional Rights) for engaging in sexual misconduct during his interactions

with two different women while on-duty as an officer with the Chattanooga Police Department

(CPD). Specifically, Count One charged the defendant with willfully depriving K.B.V. of liberty

without due process of law, which includes her right to bodily integrity, when he sexually

assaulted her while she was in the defendant’s custody. As a result, K.B.V. sustained bodily

injury. Count Two charged the defendant with willfully depriving D.H. of her right to be free

from unreasonable seizure when he refused to exit D.H.’s vehicle and blocked D.H. from doing

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 so. The defendant held a dangerous weapon, i.e., a taser, against her leg, and made D.H. fear that

he would sexually assault or kill her. The maximum penalty for each count is 10 years in prison.

As set forth in the Presentence Report (PSR), the federal investigation established that the

defendant, in addition to the two crimes set forth in the Information, sexually assaulted two more

women while serving in his capacity as a police officer. As part of the plea agreement, the

defendant admitted that he also committed these additional uncharged sexual assaults.

II. OFFENSE CONDUCT AND UNCHARGED RELEVANT CONDUCT

The defendant’s guilty plea establishes that the defendant repeatedly violated the

Constitution by engaging in a pattern of predatory behavior against women with whom he came

into contact during the course of his duties. All four assaults warrant significant punishment. A

fifth assault, about which the United States learned after the defendant entered his guilty plea,

and although beyond the reach of federal jurisdiction, establishes that the defendant’s predatory

behavior was not confined to his actions as a police officer.

A. Conduct of the Charged Offenses

For Count One, during the early morning hours of June 12, 2018, the defendant, while on-

duty as a CPD police officer, handcuffed and arrested K.B.V. Rather than transporting K.B.V.

directly to the Hamilton County Jail, he drove K.B.V. in his squad car to an empty and isolated

parking lot. There, the defendant, without K.B.V.’s consent, penetrated K.B.V. 's vagina with his

penis, resulting in vaginal pain and bruising to K.B.V.

As to Count Two, on the evening of January 2, 2016, the defendant, while working a security

detail at the University of Tennessee in Chattanooga, entered the passenger seat of D.H.'s car and

asked for a ride to his own car, which he claimed was parked in a different parking lot. The

defendant then directed D.H. to an empty and isolated parking lot. He took out his taser and put

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 it against D.H.'s leg, causing D.H. to fear for her physical safety. When D.H. tried to get out of

her car to escape, the defendant prevented her from doing so, making D.H. believe that he was

going to rape and possibly kill her. The defendant ultimately got out of her car without causing

significant physical harm to D.H., though the trauma of the defendant’s conduct has long since

stayed with her. (See Victim Impact Statement, Exhibit 1).

B. Uncharged Relevant Conduct Set Forth in the Plea Agreement

The two additional uncharged sexual assaults described in the plea agreement follow the

same pattern as the defendant’s sexual assault of K.B.V., as charged in Count One. During the

night of July 31, 2015, the defendant, while on-duty as a CPD police officer, arrested T.L. Rather

than transporting her to the Hamilton County Jail, the defendant drove T.L. in his squad car to a

secluded area where, without her consent, he penetrated her vagina with his penis.

T.L. immediately reported the sexual assault to CPD, and underwent a sexual assault nurse

examiner’s (SANE) exam or rape kit. That evidence remained untested by CPD until years later,

when K.B.V. reported the defendant and the FBI launched an investigation.

The second uncharged sexual assault occurred during the night of May 30, 2016, when the

defendant, while on duty as a CPD police officer, arrested S.M. Rather than transporting S.M. to

the Hamilton County Jail, the defendant drove S.M. to a secluded area, where, without her

consent, he made S.M. put her mouth on his penis.

C. Newly-Discovered Uncharged Relevant Conduct

During the evening of August 8, 2015 – just over a week after the defendant had sexually

assault T.L. – N.S. and her then-boyfriend went out socially with the defendant and other friends.

They all slept at the defendant’s house. N.S. and her then-boyfriend slept on the couch. Her

boyfriend woke up early on the morning of August 9, and went to work. N.S. remained asleep,

but awoke to find the defendant penetrating her vagina with his penis without her consent.

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 N.S. immediately disclosed the sexual assault to her mother and then-boyfriend, and

confronted the defendant via a direct message on social media to which the defendant replied

with an apology. However, N.S. did not officially report the defendant at the time because he

was a new police officer. She did not think anyone would believe her, and only recently

contacted the FBI because she learned through news reports that the defendant had pleaded

guilty to similar crimes. N.S. lives with guilt, believing that had she immediately reported the

defendant, he might not have been able to victimize other women (See Victim Impact Statement,

Exhibit 2).

III. ARGUMENT

The gravity of the defendant’s conduct unquestionably warrants a long prison sentence. The

plea agreement provides for a maximum sentence of 20 years and holds the defendant publicly

accountable for his admitted commission of four assaults. In structuring the plea agreement, the

United States sought to vindicate the rights of the four victims, but spare them the uncertainty of

trial and the trauma endemic to testifying about the degrading and intimate nature of sexual

assault. With this plea, the United States also endeavored to guarantee that the victims and the

community at large would be protected from the defendant. A sentence of not less than 17 years

in prison will both account for the gravity and scope of the defendant’s misconduct and comport

with the sentencing factors set forth in 18 U.S.C. § 3553. 1

A. The Court Should Consider the Full Scope of the Defendant’s Misconduct When
Imposing Sentence

1
In estimating the potential advisory guidelines range, the parties discussed that the sentencing guidelines range
could be 13.5 to 17 years. However, the United States frequently reiterated to the defendant’s attorney that its
calculations could be incorrect, and that the Court has full discretion over sentencing, to include imposing the
statutory maximum sentence of 20 years in prison. Moreover, paragraph 5, subsection (c) of the Plea Agreement
(Doc. 2) explicitly states that any “estimates or predictions” as to a potential sentence is “not binding on the Court,”
and that the defendant “understands that the sentence in this case will be determined by the Court after it receives”
the PSR.

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 The defendant committed multiple sexual assaults, and in so doing, repeatedly and with

impunity violated the constitutional rights of his victims. He should be punished accordingly.

The defendant’s sentence “‘should reflect the gravity of the defendant's conduct’” and “‘be of a

type and length that will adequately reflect, among other things, the harm done or threatened by

the offense.’” United States v. McQueen, 727 F.3d 1144, 1157 (11th Cir. 2013)) (quoting S.Rep.

No. 98–225, at 75–76 (1983)). The true depth of the harm the defendant inflicted on his victims

and on the community he was sworn to protect becomes even more clear when looking at his full

range of his crimes. While the two crimes charged in the Information alone warrant a substantial

sentence, the depravity of the defendant’s multiple crimes coupled with the number of victims

further justify this Court’s imposition of a lengthy sentence.

The Supreme Court has repeatedly held that a trial court can and should consider uncharged

relevant conduct when imposing a sentence in order to fully understand the scope of the

defendant’s conduct. United States v. Watts, 519 U.S. 148, 151–52, (1997) (internal citations

omitted) (“Highly relevant-if not essential [to the judge’s] selection of an appropriate sentence is

the possession of the fullest information possible concerning the defendant's life and

characteristics.”). This includes a defendant's past criminal conduct, even if such conduct did not

result in a conviction or is beyond the reach of federal jurisdiction. Nichols v. United States, 511

U.S. 738, 747 (1994); see also Edwards v. United States, 523 U.S. 511, 513–14 (1998); United

States v. Mustafa, 695 F.3d 860, 862 (8th Cir. 2012) (a court may rely upon uncharged relevant

conduct to enhance a sentence imposed within statutory limits); United States v. Hough, 276

F.3d 884, 898 (6th Cir. 2002) (affirming that a trial court may consider “any relevant conduct”

during sentencing even if that conduct is not a federal crime). Indeed, the United States

Sentencing Guidelines specifically notes that a “plea agreement . . . containing a stipulation that

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 specifically establishes the commission of additional offenses,” as is the case here with the

defendant’s admission of two additional sexual assaults, “shall be treated as if the defendant had

been convicted of additional counts charging those offenses.” U.S.S.G. § 1B1.2(c). To that end,

the PSR correctly includes the two uncharged sexual assaults listed in the plea agreement in the

calculation of the advisory sentencing range.

Therefore, to impose a sentence that fully captures the gravity and scope of the defendant’s

misconduct, this Court should consider the two additional uncharged sexual assaults to which the

defendant admitted guilt as part of his plea agreement, as well as the aforementioned newly-

discovered sexual assault committed by the defendant.

B. Section 3553 Sentencing Factors Warrant a Substantial Prison Sentence

A sentence of not less than 17 years is by no means greater than necessary to achieve the

sentencing purposes set forth in 18 U.S.C. § 3553. A lengthy prison sentence adequately reflects

the nature and circumstances of the defendant’s pattern of predatory behavior, ensures justice for

the victims, reflects the seriousness of the offense, promotes respect for the law, provides just

punishment for the defendant’s offenses, and will remind the community that law enforcement

officers are not above the law and will be held to account for their crimes. Furthermore, a long

sentence will hopefully deter the defendant from ever committing such crimes again, but in the

meantime, the longer the defendant is in custody, the longer the public will be safe from him.

An officer’s abuse of authority is a betrayal of the public trust, and the manner in which the

defendant did so is particularly egregious. Courts have held that where law enforcement officers

abuse their positions of authority, such offenses should be treated more seriously than crimes

committed by private citizens. See United States v. Thames, 214 F.3d 608, 614 (5th Cir. 2000)

(“[A] defendant’s status as a law enforcement officer is often times more akin to an aggravating

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 as opposed to a mitigating sentencing factor, as criminal conduct by a police officer constitutes

an abuse of a public position.”); United States v. Hebert, 813 F.3d 551, 563 (5th Cir. 2015)

(affirming an upward variance in the sentencing of a defendant-officer based on the district

court’s finding that the defendant abused his position of trust when committing the offense). This

is certainly true for officers who exploit their authority to commit sexual assault. The Sentencing

Guidelines reflect this principle by imposing a six-level enhancement for crimes committed

under color of law. See U.S.S.G. § 2H1.1. A significant prison sentence will convey the

seriousness of the defendant’s systematic abuse of women over whom he had authority.

Such a sentence should also signal to the community and to law enforcement that officers

who violate citizens’ constitutional rights, especially by assaulting women in their custody, will

face serious consequences. See United States v. Hooper, 566 F. App’x 771, 773 (11th Cir. 2014)

(citing McQueen, 727 F.3d at 1144 (11th Cir. 2013)) (declaring that the need for “general

deterrence is especially compelling in the context of officials abusing their power.”). Deterrence

is particularly important where law enforcement officers abuse their authority, as they occupy

positions that “‘provid[e] the freedom to commit a difficult-to-detect wrong.” United States v.

Cui, 106 F.3d 409, 2 (9th Cir. 1997)(internal quotations omitted). There are few crimes more

difficult to detect than sexual assault, when there are rarely independent witnesses, and the case

is often reliant on the credibility of the victim.

Indeed, the defendant clearly believed that he could exploit his authority as a police officer in

order to sexually assault women and get away with it. He drove to secluded locations to avoid

detection, and he chose victims whom he thought no one would believe, essentially creating

situations where it would be his victim’s word against his, should any victim prove brave enough

to report his criminal conduct. It is for these very reasons that the defendant escaped

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 accountability for so long. A significant sentence should remind law enforcement that when

officers commit crimes while acting under color of law, they in fact will not escape

accountability. Moreover, the timeline of the defendant’s crimes, and more particularly, the

initial report from one of his victims in 2015, should serve as a stark reminder to authorities that

sexual assault allegations should not be dismissed out-of-hand just because the victim is in

custody or the subject is a police officer.

C. Consistent with the Sentencing Guidelines, the Court Should Impose a Sentence
of No Less than 17 Years, and There is No Basis for a Departure or Variance

The Supreme Court has held that although the Guidelines are advisory in nature, courts

“must consult these Guidelines and take them into account when sentencing.” United States v.

Booker, 543 U.S. 220, 264 (2005). The Supreme Court has further emphasized that a district

court must begin its sentencing proceedings by correctly calculating the applicable sentencing

range, which serves as “the starting point and the initial benchmark.” Gall v. United States, 552

U.S. 38, 49 (2007). Trial courts may depart below a defendant’s advisory range based on a

variety of factors, only if those factors are present “to a degree substantially in excess of, or

substantially below, that which is ordinarily involved in that kind of offense.” U.S.S.G. §

5K2.0(2)-(3).

There are no such factors here to warrant a departure. The Guidelines recommendation of life

in prison reflects the gravity of the defendant’s crimes. The defendant has already received the

benefit of a 20-year statutory maximum sentence by pleading guilty early and avoiding

additional charges. The United States is simply asking the Court to sentence the defendant

commensurate with his crimes, and provide him no more of a benefit than he has already

received under the terms of his plea agreement.

IV. CONCLUSION

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 The United States respectfully submits this sentencing memorandum and requests the Court

impose a sentence of not less than 17 years in prison. Such a sentence is consistent with the

sentencing factors set out in 18 U.S.C. § 3553(a), vindicates the victims’ constitutional rights,

protects the public from the defendant, and reflects the gravity of the defendant’s conduct.

Respectfully submitted,

J. DOUGLAS OVERBEY
United States Attorney

JAMES T. BROOKS
Assistant United States Attorney

ERIC S. DREIBAND
Assistant Attorney General
Civil Rights Division
U.S. Department of Justice

FARA GOLD
Special Litigation Counsel
Civil Rights Division, Criminal Section

OLIMPIA E. MICHEL
Trial Attorney
Civil Rights Division, Criminal Section

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 CERTIFICATE OF SERVICE

I hereby certify that on August 4, 2020, notice of the foregoing was filed electronically
and was sent by operation of the Court’s electronic filing system to all parties indicated on the
electronic filing receipt. A true and exact copy of this was sent by electronic mail to the
probation office and the defendant’s attorney.

_______________________________
FARA GOLD
Special Litigation Counsel

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 July 20, 2020 US v. Logan

Victim Impact Statement from DH:

This crime has really affected me in a lot of ways. The night that he did this to me was his very first night
working there and I had no reason to think that he would change my life so much in a bad way. I was
barely afraid of anything before this happened to me and now I am afraid to get out on the street by
myself. I am someone that needs to walk for my health and to help with anxiety and because of this
man, my current husband who can’t walk has to follow me in the car as I walk because I’m so nervous
now. Police cars now also frighten me and I have never in my life feared law enforcement. In fact, my
dad brought me up to always respect law enforcement and the military, and this man took that trust
away from me. I now have severe bouts of depression and because I can’t afford the depression
medication, I have had to get on Medicare.

It has not only affected me. Look what it has done to him. This man has a young child. How is this going
to affect his child’s life? What has this done to his wife’s life? Look at what he has done to his family, to
the people he raped and assaulted, look at what he’s done to his police officer colleagues? Does he
want his little boy to grow up and be like him?

This has changed my whole life and I have at times felt that I would never get better. I told my family
what had happened because I wanted them to understand why I had changed, why I didn’t cook for
them anymore, why I had changed everything about me, the confident happy person I used to be –
because that night had changed my whole life. I want the Judge to know that even though at that time I
felt like I ‘d never be the same, I am better now.

I don’t know what I would say to him because I don’t think he cares. I would never want to hurt anyone
– I don’t understand people like him. People deserve to be treated like human beings – I don’t think
saying that to him would make a difference to him.

I think he should get as many years for what he has done to these other women that the law will allow
because do I think he’s going to change? No! In my opinion I think he enjoyed every second of terrifying
me. Can you imagine the damage he has done to those women that he actually raped?

He didn’t rape me but he teased and terrified me and I know I am deeply affected by this. So can you
imagine how terrified these other women were that a police officer put them under arrest and raped
them?

I want him to know that I am very pleased that he was caught and that he will be punished and that I
could be a deciding factor in that. I would not want him to raise his son in any way that would cause his
son to be like he is. This way he cannot have an impact on his son. This way he’ll be away from his son.
He could have been a huge influence on his son as a police officer. What child wouldn’t be proud of his

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 police officer dad? And I hope he has to sit in a jail every day and think about his little boy. That poor
boy has to be ashamed that his dad has to be a rapist in prison. And imagine the financial burden that
this put on his wife and little boy.

I am grateful that he didn’t do worse to me that night but he did take away my trust in others, my
feeling of safety, and he destroyed good relationships I had at work with other law enforcement. They
didn’t know how to handle what had happened to me and I feel like he took those friendships from me.

Thank you Your Honor, for giving me this opportunity to be heard.

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 VICTIM IMPACT STATEMENT – N.S.

How has this crime affected you and those close you to you?
{e.g. feelings of anger, rage, blaming self, or family helplessness, vulnerability, fear, paranoia,
hopelessness, frustration, loss of trust and faith in the world.}

What he did to me years ago has affected me in many different ways and aspects of my life.
After learning of the additional incidences involving the other victims, I have felt an excessive
amount of sadness, fear, and vulnerability. I have a deep sense of guilt that had I been strong
enough and been more willing to report what he did to me sooner than maybe he would have
been stopped there and wouldn’t have done so many awful things to the other victims. I
honestly didn’t know what to do after he assaulted me. I was in disbelief and just wanted to
push it far away from my mind. I was so scared too. I found myself putting his life before mine
in a way because I wanted to give him the benefit of the doubt. I wanted to think he really
wasn’t that kind of person, and all I did was sacrifice myself because it affected me negatively. I
was never able to tell my father, and that hurts me to my core. I did tell my mother right after it
happened, and she was crushed but was also someone who didn’t know what to do with the
information. She always seemed to struggle in finding the right ways to support me when it
came to the sexual assault. I had pretty significant issues trusting people after he did what he
did to me. It certainly has affected the way I look at law enforcement, like “how could someone
in uniform do this to someone else?” I am a police officer now myself and can’t imagine abusing
my authority.

How has this crime affected your ability to perform your work, make a living, run a
household, go to school, or enjoy any other activities you previously performed or enjoyed?
{e.g. overreact to situations, overprotective of family members, socially withdrawn, fear of
going out in a world that has been proven unsafe.}

I feel that the assault has affected everything in my life. The assault changed every relationship
in my life by causing me to be untrusting of most people. Since the assault, I don’t feel safe, and
I feel as if people have alternative motives or are dishonest. I hate even to say this, but I doubt
everyone in my life, including myself sometimes. To this day, I feel if I could allow this to
happen to myself, what will the other people in my life, let to happen to me, or better yet how
will they hurt me themselves. I know this is not a normal or healthy way to look at the world,
especially being a police officer myself. I hate that I doubt others, and I have to work so hard
daily to trust others again because that is not a healthy or productive way to look at the world. I
have attended counseling for about two years until my insurance plan was changed, and I lost
that support. Luckily my position in my job allowed me to help people in need and show them
other people are willing and able to help them. Helping others is one of the few things I found
to bring me joy after my assault. I think assisting others brings me so much joy because I still

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 remember how fearful, distant, and misunderstood I felt. If someone could have done that for
me, it would have made a significant difference to me. Thankfully because I am in law
enforcement, I met a local victim’s advocate, and she has helped me a lot. If not for her helping
me through the emotional healing process, I don’t know if I would be able to come forward
now to write this statement.

If you wish, you may use this space to tell the Judge whatever you would like him/her to
know about how it is to be a victim of violent crime; or any other information you would like
to share.
{e.g. the stigma of being a victim, media coverage, family reaction, the loss of control.}

This has been one of the hardest things for me, understanding what happened to me, accepting
it, and accepting that he did go on to do it to other women. I live with so much guilt because I
didn’t report him after it happened. Now I am always stuck wondering if I had, would he have
stopped, and could I have prevented others from being assaulted.
I worried that no one would believe me, or people would think I was somehow to blame and
that I was screwing up a good man’s life. He was engaged at the time, and I honestly worried
that I would be perceived as the cause of this. All these years later, I am stronger, braver, and
mostly proud of myself for being able to talk about what happened to me. Nothing will ever
take away what happened to me, but I know that I am a greater, stronger, person, and none of
it was not my fault.

Reactions, feelings toward the criminal justice system:

{e.g. How the process impacted on you, how you/your family were treated; e.g.
victim/witness intervention; information on court proceedings and case status; feeling
abandoned by the system, defense attorney’s insinuations, how it felt enduring the trial,
seeing the offender face to face (plea bargaining).}

This is different for me because I know I am not a listed victim in this case, so I didn’t have to go
through what the other women went through in terms of the trial process. I do know that even
talking about what happened to me with the prosecutors on this case has been incredibly
challenging and brings me a lot of pain. I am incredibly emotional about it. I do feel believed,
and the prosecutors and the victim advocate have been incredible to me in including me with
this part, writing a statement. I feel heard and am grateful for the opportunity to say how this
has affected me. I know that this is helping me by talking about it and sharing how this type of
trauma makes a person feel.

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 Recommendations for sentencing (mandatory/maximum):
{Do you want to be notified what the sentence is, how it computes to actual time served,
when this individual comes up for parole? See attached pamphlet “Victims Right in the Parole
Process”.}

I definitely would like to know what happens to him at the sentencing hearing. I can’t imagine
what kind of sentence or punishment could ever fix what is wrong with him. I’d love to believe
that he could be rehabilitated with counseling, but I don’t see that as the fix for him. He is a
predator in a uniform, and I don’t know how he can even sleep at night. A person who can
sexually assault one person, let alone many people, needs to be put away for a long time never
to hurt anyone again. He has hurt many people along the way already, and I hope and pray that
he will never hurt anyone again. This man was a police officer, someone people looked up to,
his family looked up to, and all while he was sexually assaulting women. He didn’t just sexually
assault me, no he sexually assaulted the daughters, mothers, sisters, and friends of many
people. He could have stopped at any time, but he didn’t stop until he was caught. So I feel it is
unlikely he will change after confessing to this. After he sexually assaulted me, I confronted
him, and he still went on to hurt other people just like he did me. He’s sick and can’t be fixed.
As much as I don’t want to believe he could be, I think some people are unfixable. I know the
court will do what is right for this situation and all of the victims. Thank you for taking the time
to read my statement.

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