Case 2020CF000612 Document 2 Filed 06-11-2020 Page 1 of 4

FILED
06-11-2020
Clerk of Circuit Court
Kenosha County
STATE OF WISCONSIN CIRCUIT COURT KENOSHA COUNTY
2020CF000612
STATE OF Wisconsin Honorable Bruce E.
CRIMINAL COMPLAINT Schroeder
Plaintiff,
Branch 3
vs. DA Case #: 2020KN002414

ROBERT D. CARVER Agency Case #: KPD 2020-00027412

4515 121st Street
Pleasant Prairie, WI 53158 Mandatory date
DOB: 09/27/1941
Sex/Race: M/W
Eye Color: Green
Hair Color:
Height: 5 ft 10 in
Weight: 180 lbs
Alias:
Defendant. For Official Use

The undersigned, being first duly sworn, states that:

Count 1: DISORDERLY CONDUCT, HATE CRIME

The above-named defendant on or about Tuesday, June 2, 2020, in the City of Kenosha, Kenosha
County, Wisconsin, while in a public or private place, did engage in violent, abusive, indecent,
profane, boisterous, unreasonably loud or otherwise disorderly conduct, under circumstances in
which such conduct tended to cause or provoke a disturbance, contrary to sec. 947.01(1),
939.51(3)(b), 939.645(1) and (2)(a) Wis. Stats., a Class B Misdemeanor, and upon conviction may
be fined not more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90)
days, or both.

And further, invoking the provisions of sec. 939.645(1) and (2)(a) Wis. Stats., because the
defendant committed a crime under chapters 939 to 948, and intentionally selected the person
against whom the crime was committed in whole or in part because of the defendant's belief or
perception regarding the race of that person, the revised maximum fine is $10,000 and the revised
maximum term of imprisonment is one year in the county jail.

Count 2: ENDANGERING SAFETY BY USE OF A DANGEROUS WEAPON, HATE CRIME

The above-named defendant on or about Tuesday, June 2, 2020, in the City of Kenosha, Kenosha
County, Wisconsin, did endanger another's safety by the negligent operation of a dangerous
weapon,, contrary to sec. 941.20(1)(a), 939.51(3)(a), 939.645(1) and (2)(b) Wis. Stats., a Class A
Misdemeanor, and upon conviction may be fined not more than Ten Thousand Dollars ($10,000),
or imprisoned not more than nine (9) months, or both.

And further, invoking the provisions of sec. 939.645(1) and (2)(b) Wis. Stats., because the
defendant committed a crime under chapters 939 to 948, and intentionally selected the person
against whom the crime was committed in whole or in part because of the defendant's belief or
perception regarding the race of that person, the penalty increase under this section changes the
 Case 2020CF000612 Document 2 Filed 06-11-2020 Page 2 of 4

status of the crime to a felony and the revised maximum fine is $10,000 and the revised maximum
term of imprisonment is 2 years.

PROBABLE CAUSE:

Officer Sanderson of the Kenosha Police Department reports that on June 2, 2020 at
approximately 9:04 am, he and other officers responded to Menards located at 7330 74 th Place
which is in the City and County of Kenosha, State of Wisconsin.

Upon arrival, Officer Sanderson spoke with Cassandra Harris. Ms. Harris stated to Officer
Sanderson that she was returning to her vehicle in the parking lot of Menards when she had a
verbal altercation with an older, white male regarding the placement of her shopping cart. Ms.
Harris stated that this male was verbally assaulting her and used racial slurs. Ms. Harris is an
African American woman. Officer Sanderson reports that Ms. Harris was visibly upset, shaking at
times and crying.

Ms. Harris provided a signed, written statement. Ms. Harris stated that she had completed
shopping and returned to her vehicle which was parked facing east in the 3 rd stall of the 3rd row in
front of the Menard’s main entrance. Ms. Harris stated that she unloaded her shopping cart and
was moving her cart towards a light pillar near where she was parked. Ms. Harris stated that at
this time a white male who appeared to be returning to his parked vehicle shouted over to her
something like, “You n----r. Don’t leave that cart right there!” This male was later identified as
Robert Carver (hereinafter “the defendant”).

Ms. Harris stated that she told the defendant he shouldn’t talk to her that way and he needed to
stop. Ms. Harris stated that she attempted to tell the defendant that she was trying to move her
cart amongst all the vehicles and traffic. Ms. Harris stated that the defendant then said, “You are a
lazy n----r!” Ms. Harris stated that she told the defendant he was being ridiculous and had no right
to treat anyone this way because he was white and she was black. Ms. Harris stated that she told
the defendant to stop calling her the n-word and she asked what his problem was. Ms. Harris
stated that the man continued to yell at her and called her racial names multiple more times and
told her to “f--k herself” and called her “a motherf---er.”

Ms. Harris stated that the defendant got into his car, a black Hummer. The defendant’s vehicle
was parked in the same 3rd row of parking stalls as Ms. Harris’s vehicle, but was facing west. Ms.
Harris stated that the defendant backed all the way out of the parking stall, at least a full car length,
and then quickly accelerated back through the stall at her. Ms. Harris quickly jumped out of the
way. Ms. Harris stated that another person started yelling at the defendant and telling him to stop.
Ms. Harris stated that the defendant was yelling at this other person and then back towards her,
calling her “a n----r.” Ms. Harris stated that the defendant then sped off, headed out of the parking
lot to the east. Ms. Harris stated that she believed the defendant was trying to hit and kill her and
that if she would not have jumped out of the way he would have hit and harmed her or killed her.

Officer Block of the Kenosha Police Department reports that he spoke with David Herek. Mr.
Herek stated he was walking from his car to the Menard’s entrance when he overheard multiple
people yelling, one male (later identified as the defendant) and one female (later identified as Ms.
Harris). Mr. Herek stated that the defendant screamed “lazy n----r” and Ms. Harris yelled back, “I
am not that.” Mr. Herek stated that several words were exchanged and the defendant closed his
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car door to his black Hummer and backed up. Mr. Herek stated that that this point he was a foot
away from the Hummer. Mr. Herek stated the defendant pulled halfway out, put it in gear, and
then hit the gas, lunging forward towards Ms. Harris. Mr. Herek stated that the defendant’s forward
speed was not normal and he was possibly looking to scare or harm Ms. Harris. Mr. Herek stated
that he ran at the car, punched the window scaring the defendant and exchanged words with the
defendant. Mr. Herek stated that the defendant yelled back and backed out, flipping them off.

Officer Grabot of the Kenosha Police Department spoke to Noah Reeves, a Menard’s employee.
Mr. Reeves stated that he was working, gathering carts when he heard arguing in the parking lot
and saw a male subject (later identified as the defendant) yelling at a female subject (later
identified as Ms. Harris). Mr. Reeves stated that the defendant called Ms. Harris “a n----r.” Mr.
Reeves stated that Ms. Harris started yelling at the defendant. Mr. Reeves stated that the
defendant then backed out of his space and stopped. Mr. Reeves stated that the defendant then
pulled forward at about 5 mph towards Ms. Harris who was standing between a light pole and her
vehicle. Mr. Reeves stated that he thought the defendant was going to hit Ms. Harris. Mr. Reeves
stated that all of a sudden another customer (later identified as Mr. Herek) started banging on the
driver’s window of the Hummer and the defendant stopped his vehicle. Mr. Reeves stated that the
defendant rolled down his window and Mr. Herek told the defendant that he had no right to do what
he was doing. Mr. Reeves stated that his manager started to come out to the parking lot. Mr.
Reeves stated that the defendant then backed out of the parking space again and left the parking
lot in a hurry.

Officer Grabot reports that the plate of the vehicle came back registered to Robert Carver, the
defendant. Officer Grabot and Officer Block attempted to make contact with the defendant at his
residence, but no one was home. Dispatch then advised that the defendant was back at Menard’s.
Officer Grabot and Officer Block went back to Menard’s and met with the defendant there. Officer
Block reports that the defendant denied using any racial slurs towards Ms. Harris. Officer Block
reports that the defendant admitted he did drive forwards because Ms. Harris was coming at him.
Officer Block reports that none of the parties were familiar with each other. Menard’s indicated to
Officer Block that they did not want the defendant back on the property of Menard’s.

Your complainant has viewed a video which appears to have been posted on Facebook and which
appears to have captured part of this incident at Menard’s. In the video, Ms. Harris can be heard
yelling something to the effect of, “I’m out here being black, that’s a crime?” Ms. Harris appears to
be addressing the driver of a black Hummer. At that time, the Hummer is reversing out of its
parking space moving towards the west. Ms. Harris is standing in front of the Hummer and directly
behind her is a row of cars parked facing east. The Hummer then stops backing and accelerates
forwards (east) towards Ms. Harris who has to quickly move to her left to avoid being hit. The
video then shows Mr. Herek approach the driver’s side window of the Hummer and pound on the
driver’s side window, confronting the driver, the defendant. The video then shows the Hummer
backing up and then driving away to the south as Ms. Harris and Mr. Herek yell at the defendant
about what had just occurred.

Your complainant is an attorney with the Kenosha County District Attorney’s Office, who bases his
knowledge of this complaint on:

 The official law enforcement agency reports of the Kenosha Police Department prepared by
Officer Sanderson, Officer Grabot, and Officer Block, which reports were prepared in the
normal course of law enforcement duties;
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 Statements by citizen informant(s) Cassandra Harris, David Herek, and Noah Reeves; who
are eyewitnesses to the facts they relate;
 Statements by the defendant, which were made contrary to his penal interests;
 The official records of: The Circuit Court for Kenosha County; The Department of
Transportation; The FBI Triple I Teletype; The Wisconsin Circuit Court Automated Program,
which records are maintained in the normal course of business duties.

Subscribed and sworn to before me on 06/11/20 Electronically Signed By:

Electronically Signed By: Michael D. Graveley
Carli A. McNeill Complainant
Assistant District Attorney
State Bar #: 1081400