Complaint No. 1781999237 - 1173150660

This formal complaint is submitted under Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972), and pursuant to Washington State law regarding officer conduct, evidence preservation, and mandatory reporting. Officer Jorge Perez-Gutierrez was the responding and arresting officer in OPD Case Nos. 2026-03017 and 2026-03123. The documented record — drawn entirely from OPD’s own reports, CAD logs, dispatch notes, and the arrest record — raises serious, documented concerns about Officer Perez-Gutierrez’s credibility as a witness, his selective enforcement of the law, his failure to preserve critical child-exploitation evidence, his omission of material facts from sworn reports, and his failure to follow mandatory child-safety protocols.

These concerns are directly material to the pending felony harassment prosecution of Adrian Farrel Boyce (OPD Case No. 2026-03017), in which Officer Perez-Gutierrez is the primary reporting officer and the case was referred to the Thurston County Prosecutor by Perez-Gutierrez himself. Any prosecution relying on his reports, testimony, or investigative conclusions must account for the credibility and conduct issues documented herein.

SECTION 4 — DOCUMENTED VIOLATIONS AND MISCONDUCT
The following nine violations are drawn from OPD’s own records, CAD logs, dispatch notes, and sworn narratives. Each item is sourced and documented.

Violation 1: Failure to Investigate an Admitted Firearm Crime Against Minor Children
Source: OPD Case No. 2026-03017 (Narrative, pg. 4–5); CAD Log Call ID 261520891; OPD Case No. 2026-03123 (Narrative, pg. 4)
Zachary A. Vassar admitted on a recorded dispatch line to pulling and aiming a loaded firearm at Adrian Boyce while two minor children — Railee Boyce (age 9) and Zhavia King (toddler) — were standing directly beside their father. Officer Perez-Gutierrez documented this admission in related records but took no enforcement action against Vassar. He filed no charges and made no arrest under:
• RCW 9.41.230 — Aiming or Discharging Firearms (gross misdemeanor)
• RCW 9.41.270 — Unlawful Carrying or Handling of a Firearm
• RCW 9A.36.050 — Reckless Endangerment (substantial risk of death or serious physical injury to another person)
Instead, Officer Perez-Gutierrez focused his investigation on arresting the unarmed Black father, Adrian Boyce, based on the same neighbor’s verbal complaint. The contrast between Vassar’s admitted, documented firearm conduct and the absence of any charge or enforcement action is a material failure documented within Perez-Gutierrez’s own reports.

Violation 2: Selective Enforcement and Racial Bias
Source: OPD Case No. 2026-03017 (Arrest Report); OPD Case No. 2026-03123 (Narrative); Academic Analysis, Valerie King / Evergreen State College, June 7, 2026
Officer Perez-Gutierrez arrested an unarmed Black father (Adrian Boyce) for felony harassment based on a verbal complaint from Zachary A. Vassar — a white male who, on a recorded dispatch line, admitted to a more serious and documented offense: aiming a loaded firearm at Boyce with minor children present. No enforcement action was taken against Vassar.
This constitutes a documented disparity in the application of the law by the same officer in the same fact pattern, in potential violation of:
• OPD Policy 401 — Bias-Based Policing
• RCW 43.06C — Washington Law Against Discrimination in Law Enforcement
• 14th Amendment, Equal Protection Clause (selective enforcement)

Violation 3: Failure to Document Minor Children as Victims or Witnesses
Source: OPD Case No. 2026-03017 (Narrative, pg. 4–5); OPD Case No. 2026-03123 (Narrative, pg. 4–5)
Officer Perez-Gutierrez explicitly characterized Railee Boyce and Zhavia King as “uninvolved” in his narrative. Both children were present during and directly exposed to Vassar’s admitted firearm-brandishing incident. Under Washington law and OPD policy, their status as minor victims or witnesses required documentation and referral:
• OPD Policy 422 — Victim and Witness Assistance
• RCW 26.44.030 — Mandatory reporting of child abuse and neglect
• RCW 9A.36.050 — Reckless Endangerment (children as direct victims of the firearm conduct)
By omitting the children as victims, Perez-Gutierrez effectively erased them from the evidentiary record and precluded appropriate child-safety referrals, DCYF notification, or trauma-informed response.

Violation 4: Arrest of Adrian Boyce While Boyce Was Actively Reporting a Missing Child to Dispatch
Source: CAD Log, Call ID 261560874 (OPD Case No. 2026-03123); OPD Case No. 2026-03123 (Narrative, pg. 3–5)
The CAD log for Call ID 261560874 documents that on June 5, 2026, Adrian Boyce himself called dispatch to report that his daughter Railee was missing and that a male with a firearm had been involved. Officer Perez-Gutierrez arrived at 1209 Fern St SW F-301 in response to that very call. Upon arrival, rather than taking Boyce’s child-safety report, Perez-Gutierrez arrested Boyce for the June 1, 2026 felony harassment charge.
The effect was to silence a parent’s active missing-child and potential child-exploitation report at the moment it was being made. The child-safety concern about Railee’s missing status and subsequent exploitation was never addressed in that police contact. This represents a failure of duty to Railee Boyce as a potential child victim.

Violation 5: Failure to Preserve Critical Child-Exploitation Evidence (Memphis’s Phone / Video)
Source: OPD Case No. 2026-03170 (Sgt. Hendrickson); Valerie King’s Report, Section 7; SEEK THEN SPEAK Report (June 10, 2026); Monarch Child Safety Request (June 9, 2026)
On or around June 8, 2026, Hansen Elementary School Principal Callie Jones disclosed to Valerie King that Railee Boyce had been recorded in a sexualized context on June 5, 2026, approximately 8:30 p.m. The recording was on a phone belonging to a minor child identified as Memphis. Officer Perez-Gutierrez and/or Sgt. Hendrickson failed to confiscate, secure, or preserve that phone and its contents, despite:
• RCW 9.68A — Sexual Exploitation of Minors (mandatory evidence preservation)
• RCW 9.68A.075 — Viewing / Possession of depictions of minor engaged in sexually explicit conduct
• Mandatory reporting and evidence-preservation obligations applicable to all Washington law enforcement
The phone reportedly still contained two video recordings involving Railee at the time Valerie King attempted to report this to law enforcement. Failure to secure this evidence may have allowed it to be deleted, altered, shared, or destroyed.

Violation 6: Coaching or Influencing a Child Witness’s Statement
Source: OPD Case No. 2026-03123 (Narrative, pg. 3–4, Officer Perez-Gutierrez’s own account)
Perez-Gutierrez’s own sworn narrative in Case 2026-03123 documents the following: when he asked Railee to identify who had restrained her, her father Adrian was simultaneously calling out to Railee, motioning to his face with his hand and “moving his head in an up and down motion.” Railee then “calmly confirmed” the identification “as she repeated Adrian’s up and down motion with her upper torso.”
Despite documenting this observed behavior, Perez-Gutierrez took no steps to ensure Railee’s statement was obtained independently and free from parental influence — which is a foundational requirement in child-witness interview protocols. This failure corrupts the integrity of the child’s statement and is relevant to the credibility of both the report and the officer’s investigative judgment.

Violation 7: Premature Unfounding of Child Restraint Report (Case 2026-03123)
Source: OPD Case No. 2026-03123 (Narrative and Case Status: Unfounded)
Railee Boyce reported on a recorded dispatch call (CAD Log 261560874) that a male grabbed her, covered her mouth, wrapped his arm around her to prevent her from leaving, and had a firearm in his hand. Officer Perez-Gutierrez unfounded this case primarily because location data confirmed Vassar was elsewhere — however, Railee described her assailant as wearing a mask and all-black clothing and appearing homeless. She did not affirmatively identify Vassar.
The unfounding was premature and did not account for the possibility of a different, unidentified suspect. Railee’s description was never independently investigated. Given that she was a 9-year-old child who had just witnessed her father’s arrest and was reporting trauma, the failure to conduct a proper child-centered investigation before closing the case as unfounded is a documented procedural failure.

Violation 8: Refusal to Accept Valerie King’s Separate Child-Safety / Exploitation Report
Source: Valerie King’s Report (Section 5, pg. 3); Email to Thurston County Sheriff’s Department (June 11, 2026); Monarch Child Safety Request (June 9, 2026)
After learning on June 8, 2026 of the exploitation / recording incident involving Railee, Valerie King attempted to file a separate police report with OPD. She was told that no separate report would be taken and that the officer would only add a note to the existing case. Refusing to take a report involving possible child sexual exploitation is a violation of:
• RCW 26.44.030 — Mandatory Reporting of Child Abuse
• RCW 9.68A — Sexual Exploitation of Minors (law enforcement duty to investigate)
• OPD Policy 422 — Victim and Witness Assistance
Valerie King then attempted to report through the Thurston County Sheriff’s non-emergency line, the Victim’s Advocate at the Prosecutor’s Office, and by email to the Sheriff’s Department (June 11, 2026). As of the date of that email, no follow-up, confirmation, or assigned contact had been provided.

Violation 9: Omission of Material Facts from Sworn Report — Brady / Giglio Concern
Source: OPD Case No. 2026-03017 (Sworn Narrative, pg. 4–5); CAD Log 261520891; OPD Case No. 2026-03123 (pg. 3–5)
Under Brady v. Maryland and Giglio v. United States, law enforcement is obligated to disclose material exculpatory and impeachment information to prosecutors. Officer Perez-Gutierrez’s sworn narrative in Case 2026-03017 — the case referred to the Thurston County Prosecutor for felony harassment charges against Adrian Boyce — omits the following material facts:
• That Zachary Vassar admitted on a recorded dispatch line to pulling a loaded firearm on Adrian Boyce while minor children were present
• That Vassar’s own conduct may have been the predicate provocation for any words Boyce used
• That Railee Boyce was missing or unaccounted for during the June 1 incident, providing context for Boyce’s presence outside
• That Adrian Boyce was attempting to protect his toddler from an aggressive dog when he made the statement Vassar characterized as a threat
These omissions are material to the credibility of the complaining witness (Vassar) and to the context of Boyce’s alleged statements. The failure to include them in the sworn report referred to the prosecutor constitutes a Brady material concern that must be disclosed and reviewed.

SECTION 5 — AGENCIES RECEIVING THIS COMPLAINT
This complaint is being submitted to the following:
1. Thurston County Prosecutor’s Office — Brady/Giglio list disclosure, relevant to People v. Boyce (OPD Case No. 2026-03017)
2. OPD Office of Professional Standards — Internal affairs review
3. OIR Group / Civilian Police Auditor (Stephen J. Connolly) — Currently tracking OPD investigation per Valerie King’s report
4. Thurston County Sheriff’s Department — As documented in email, June 11, 2026
5. Washington State Attorney General’s Office — Civil Rights Division
6. Washington State Criminal Justice Training Commission (CJTC) — Officer certification review
7. Monarch Children’s Justice & Advocacy Center — Child-safety and exploitation review
8. U.S. Department of Justice, Civil Rights Division — If federal civil rights violations are substantiated

SECTION 6 — EVIDENCE AND RECORDS REQUESTED FOR PRESERVATION AND REVIEW
• All 911 and dispatch audio from June 1, 2026 and June 5, 2026 (Call IDs 261520891 and 261560874)
• All CAD/dispatch logs for May 20, June 1, and June 5, 2026
• All body-worn camera footage from Officer Perez-Gutierrez for OPD Case Nos. 2026-03017 and 2026-03123
• All body-worn camera footage and notes from Sgt. Hendrickson (OPD Case No. 2026-03170)
• All officer narratives, supplements, CAD remarks, and supervisor notes (Sparks, #3991) for the above cases
• Memphis’s phone containing the two video recordings of Railee Boyce — to be preserved and handled only by authorized law enforcement or child-exploitation investigators
• School communications from Hansen Elementary Principal Callie Jones re: June 8, 2026 disclosure
• All calls, reports, or CAD logs connected to Zachary A. Vassar from May 20 through June 10, 2026
• Location data and screenshots submitted by Vassar (already uploaded to evidence.com per OPD Case No. 2026-03123)
• Court records for Thurston County District Court Case No. 26-000284 (no-contact order)

SECTION 7 — DECLARATION
I, Valerie King, declare under penalty of perjury under the laws of the State of Washington that the information in this complaint is true and correct to the best of my knowledge, information, and belief. All facts cited herein are drawn from official law enforcement records, CAD logs, dispatch notes, sworn officer narratives, court documents, and my direct personal knowledge as a witness to these events.

I understand that this complaint may be reviewed by a court, prosecutor, advocate, attorney, or law-enforcement agency. I am prepared to provide additional information, documentation, or testimony through the proper process.