1. The Affidavit for the warrant:
COPY
AFFIDAVIT
I, Christian Nelson, having first been duly sworn, do hereby state as follows:
That I, Christian Nelson, a Police Officer with the Taylorville Police Department having been a police officer for 1 year. That the facts contained in the application are based on my observation and information, as well as the information and observations of other law enforcement officers; that to the best of my knowledge, the information contained herein is true and correct.
(1). The FBI Springfield office received a tip that Todd E. Daugherty(M/W D.O.B. 07/05/1968) posted on internet social forum Hateandflame.com the following comment "Fuck you you stalking mother fuckers. I'll show you who is 'austic'. I'll go to fucking memorial elementary school and make sandy hook look like a Sunday school picnic.".
(2). Todd E. Daugherty has a HAM radio operator call sign of "N90GL". The post threatening violence against Memorial School was issued by someone with user-name "N90GL".
(3). Todd E. Daugherty has threatened violence against public officials and institutions in the past, including on June 22, 2015, and his profile picture is an image of him holding a 1911 style handgun and pointing it at a camera.
(4). Todd E. Daugherty stated that he was familiar with the website, but stated that he did not make the post. Daugherty claimed that he was being set up by another member of the online community to have his HAM radio license suspended by the FCC.
(5). The post in question from Hateandflame.com was submitted with a picture of T.Daugherty posing with and pointing a firearm at the camera. This picture was identical to T.Daugherty's profile picture that appears with his post. T. Daugherty does not posess a valid IL FOID card.
Affiant
Subscribed and sworn before me this 21th day of March 2018
ISSUES WITH THE AFFIDAVIT FOR THE SEARCH WARRANT:
Affiant Credentials
“...having been a police officer for 1 year.”
Issue: No mention of training in digital forensics, internet investigations, or cyber attribution.
Impact: Affiant lacked qualifications to assess online identity or interpret digital evidence.
Threat Attribution
“...Todd E. Daugherty posted on Hateandflame.com...”
Falsehood: No forensic evidence links me to the post.
Omission: The post came from a TOR exit node, not MY static IP.
Impact: Misrepresents authorship; foundational to probable cause.
HAM Radio Username
“...user-name ‘N90GL’...”
Falsehood: Username alone is not proof of authorship.
Omission: No metadata, login records, or IP logs tying me to the account.
Impact: Misleading attribution; no evidentiary basis.
Prior Alleged Threats
“...threatened violence... June 22, 2015...”
Falsehood: I WAS arrested in 2015, but charges were dropped.
Omission: No mention of dismissal or exoneration.
Impact: Misrepresents criminal history; prejudicial and misleading.
My Statement
“...claimed that he was being set up...”
Omission: No mention of corroborating evidence (e.g., impersonation, TOR routing, ongoing posts while jailed).
Impact: Downplays my defense and ignores exculpatory context.
Image Attribution
“...picture identical to T. Daugherty’s profile picture...”
Falsehood: The image was previously submitted by a third party in 2015.
Omission: No forensic analysis of image origin or upload metadata.
Impact: Misleading implication of authorship.
FOID Card Status
“...does not possess a valid IL FOID card.”
Irrelevant: FOID status has no bearing on authorship of the post.
Impact: Prejudicial; used to bias the judge.
COPY
AFFIDAVIT
I, Christian Nelson, having first been duly sworn, do hereby state as follows:
That I, Christian Nelson, a Police Officer with the Taylorville Police Department having been a police officer for 1 year. That the facts contained in the application are based on my observation and information, as well as the information and observations of other law enforcement officers; that to the best of my knowledge, the information contained herein is true and correct.
(1). The FBI Springfield office received a tip that Todd E. Daugherty(M/W D.O.B. 07/05/1968) posted on internet social forum Hateandflame.com the following comment "Fuck you you stalking mother fuckers. I'll show you who is 'austic'. I'll go to fucking memorial elementary school and make sandy hook look like a Sunday school picnic.".
(2). Todd E. Daugherty has a HAM radio operator call sign of "N90GL". The post threatening violence against Memorial School was issued by someone with user-name "N90GL".
(3). Todd E. Daugherty has threatened violence against public officials and institutions in the past, including on June 22, 2015, and his profile picture is an image of him holding a 1911 style handgun and pointing it at a camera.
(4). Todd E. Daugherty stated that he was familiar with the website, but stated that he did not make the post. Daugherty claimed that he was being set up by another member of the online community to have his HAM radio license suspended by the FCC.
(5). The post in question from Hateandflame.com was submitted with a picture of T.Daugherty posing with and pointing a firearm at the camera. This picture was identical to T.Daugherty's profile picture that appears with his post. T. Daugherty does not posess a valid IL FOID card.
Affiant
Subscribed and sworn before me this 21th day of March 2018
ISSUES WITH THE AFFIDAVIT FOR THE SEARCH WARRANT:
Affiant Credentials
“...having been a police officer for 1 year.”
Issue: No mention of training in digital forensics, internet investigations, or cyber attribution.
Impact: Affiant lacked qualifications to assess online identity or interpret digital evidence.
Threat Attribution
“...Todd E. Daugherty posted on Hateandflame.com...”
Falsehood: No forensic evidence links me to the post.
Omission: The post came from a TOR exit node, not MY static IP.
Impact: Misrepresents authorship; foundational to probable cause.
HAM Radio Username
“...user-name ‘N90GL’...”
Falsehood: Username alone is not proof of authorship.
Omission: No metadata, login records, or IP logs tying me to the account.
Impact: Misleading attribution; no evidentiary basis.
Prior Alleged Threats
“...threatened violence... June 22, 2015...”
Falsehood: I WAS arrested in 2015, but charges were dropped.
Omission: No mention of dismissal or exoneration.
Impact: Misrepresents criminal history; prejudicial and misleading.
My Statement
“...claimed that he was being set up...”
Omission: No mention of corroborating evidence (e.g., impersonation, TOR routing, ongoing posts while jailed).
Impact: Downplays my defense and ignores exculpatory context.
Image Attribution
“...picture identical to T. Daugherty’s profile picture...”
Falsehood: The image was previously submitted by a third party in 2015.
Omission: No forensic analysis of image origin or upload metadata.
Impact: Misleading implication of authorship.
FOID Card Status
“...does not possess a valid IL FOID card.”
Irrelevant: FOID status has no bearing on authorship of the post.
Impact: Prejudicial; used to bias the judge.