United States v. Kyle — Criminal complaint and arrest-warrant affidavit (filed May 12, 2026)

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CRIMINAL COMPLAINT, Case No. 26-mj-416-JFJ (later 4:26-cr-00189-SEH), U.S. District Court for the Northern District of Oklahoma. Filed 12 May 2026; sworn by telephone before Magistrate Judge Jodi F. Jayne. Offence: 21 U.S.C. § 841(a) and (b)(1)(A)(viii), possession of methamphetamine with intent to distribute, on or about 10 May 2026 in Tulsa County. The cover form spells the defendant's first name 'Malisa'; the affidavit spells it 'Melisa'.

This is a transcription summary of a scanned 7-page document with no text layer, read page by page on 4 October 2026. It is not the verbatim text.

AFFIANT: Evan Foster, a Tulsa County deputy sheriff assigned to the DEA as a task force officer.

THE STOP, AS THE AFFIDAVIT DESCRIBES IT: on 10 May 2026 Deputy Freddie Alaniz stopped a black Mazda CX-50 with California plates on I-44 in Tulsa 'for improper turn signal while changing lanes (approximately three times).' The sole occupant produced a Missouri licence. The affidavit says the back seats were folded flat for numerous suitcases, and that in the patrol car, while a written warning was being prepared, the driver was 'extremely nervous.' After backup arrived a certified narcotics dog alerted and deputies searched the car.

WHAT THE AFFIDAVIT SAYS WAS FOUND: large Ziploc bags of a white crystal-like substance in three suitcases, packed with dryer sheets and trash bags; a digital scale; and, in a locked box behind the driver's seat, four rubber-banded bundles of currency. A DEA agent's TruNarc field test on two bags was positive for methamphetamine. 'The package weight of all the methamphetamine taken from the suitcases was 44528.8 grams' (about 98 lb), sent to the DEA laboratory for analysis and official weight.

WHAT IT DOES NOT SAY: the affidavit does not mention the Flock and VehicleManager plate-reader queries the deputy ran before the stop, or the travel history they returned. The court's later opinion found those queries were run when 'all Alaniz knew was that the vehicle had a California license plate.' The affidavit states that it is 'intended to show merely that there is sufficient probable cause' and 'does not set forth all of my knowledge about this matter.'

The court later held the stop itself lawful, on a different basis (following too closely, 47 O.S. § 11-310), but suppressed all evidence found after the stop was extended and after the plate-reader search. The defendant has not been convicted.

DOCKET STATUS AS OF 4 OCTOBER 2026 (CourtListener RECAP): the jury trial set for 6 Oct 2026 was stricken and a status conference set for 5 Oct 2026 before Judge Hill (ECF 66, 67). A defence motion to vacate the detention order, docketed as unopposed (ECF 63), was set for hearing on 5 Oct 2026 before Magistrate Judge Mark T. Steele (ECF 65). No notice of appeal appeared on the docket. Under 18 U.S.C. § 3731 the United States may appeal a suppression order to the Tenth Circuit within 30 days.