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<p class="g-doc-text" id="page-1-text">State of Minnesota County of Hennepin
State of Minnesota,
VS.
Plaintiff,
CHRISTIAN J. CASTRO
MN
Defendant.
27-CR-26-12537
Filed in District Court
State of Minnesota 5/18/2026
District Court
4th Judicial District
Prosecutor File No.
Court File No.
COMPLAINT Warrant
26A05307 27-CR-26-12537
The Complainant submits this complaint to the Court and states that there is probable cause to believe Defendant committed the following offense(s):
COUNT I
Charge: Assault-2nd Degree-Dangerous Weapon
Minnesota Statute: 609.222.1, with reference to: 609.222.1, 609.11.5(a)
Maximum Sentence: 7 YEARS AND/OR $4,200-$14,000
Offense Level: Felony
Offense Date (on or about): 01/14/2026
Control #(ICR#): 26000126
Charge Description: That on or about January 14, 2026, in Minneapolis, Hennepin County, Minnesota, Christian J. Castro, assaulted Victim 1 while using a firearm.
Minimum Sentence: 3 YEARS
COUNT II
Charge: Assault-2nd Degree-Dangerous Weapon
Minnesota Statute: 609.222.1, with reference to: 609.222.1, 609.11.5(a)
Maximum Sentence: 7 YEARS AND/OR $4,200-$14,000
Offense Level: Felony
Offense Date (on or about): 01/14/2026
Control #(ICR#): 26000126
Charge Description: That on or about January 14, 2026, in Minneapolis, Hennepin County, Minnesota, Christian J. Castro, assaulted Victim 2 while using a firearm.
Minimum Sentence: 3 YEARS
COUNT III
Charge: Assault-2nd Degree-Dangerous Weapon
Minnesota Statute: 609.222.1, with reference to: 609.222.1, 609.11.5(a)
Maximum Sentence: 7 YEARS AND/OR $4,200-$14,000
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<p class="g-doc-text" id="page-2-text">Offense Level: Felony
27-CR-26-12537
Filed in District Court State of Minnesota 5/18/2026
Offense Date (on or about): 01/14/2026
Control #(ICR#): 26000126
Charge Description: That on or about January 14, 2026, in Minneapolis, Hennepin County, Minnesota, Christian J. Castro, assaulted Victim 3 while using a firearm. Minimum Sentence: 3 YEARS
COUNT IV
Charge: Assault-2nd Degree-Dangerous Weapon
Minnesota Statute: 609.222.1, with reference to: 609.222.1, 609.11.5(a)
Maximum Sentence: 7 YEARS AND/OR $4,200-$14,000
Offense Level: Felony
Offense Date (on or about): 01/14/2026
Control #(ICR#): 26000126
Charge Description: That on or about January 14, 2026, in Minneapolis, Hennepin County, Minnesota, Christian J. Castro, assaulted Victim 4 while using a firearm.
Minimum Sentence: 3 YEARS
COUNT V
Charge: Falsely Reporting Crime
Minnesota Statute: 609.505.1, with reference to: 609.505.1
Maximum Sentence: 90 DAYS AND/OR $1,000
Offense Level: Misdemeanor
Offense Date (on or about): 01/14/2026
Control #(ICR#): 26000126
Charge Description: That on or about January 14, 2026, in Minneapolis, Hennepin County, Minnesota, Christian J. Castro informed a law enforcement officer that a crime had been committed, or otherwise provided information to an on-duty peace officer regarding the conduct of others, knowing that such information was false and intended that the officer act in reliance upon it.
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<p class="g-doc-text" id="page-3-text">27-CR-26-12537
STATEMENT OF PROBABLE CAUSE
Filed in District Court State of Minnesota 5/18/2026
Complainant has investigated the facts and circumstances of this offense and believes the following establishes probable cause:
On January 14, 2026, at approximately 6:43:49 PM, the Minneapolis Police Department ("MPD”) received a report from a 911 dispatcher that U.S. Immigration and Customs Enforcement ("ICE") agents were engaged in a vehicle pursuit of a male traveling in a Ford Focus and that the male, later identified as Victim 2, was attempting to reach his home, which was identified as XXX 24th Ave. N. in Minneapolis, Hennepin County, Minnesota. At 6:45 PM, MPD officers took remote-control of a city camera located at the intersection of Lyndale Ave. and 24th Ave. and pointed it at the home. The camera captured a series of events that culminated in an ICE agent, later identified as Christian Castro (hereinafter “Defendant”), firing a gunshot into the home, knowing it was occupied by multiple individuals, and injuring a male, later identified as Victim 1.
Video of Incident
The shooting of Victim 1 led to an investigation conducted by the Minnesota Bureau of Criminal Apprehension ("BCA"). As part of its investigation, the BCA recovered footage from the city camera at Lyndale and 24th, which captured the following events:
At 6:47 PM, Victim 1 stepped onto the front lawn of the home holding a snow shovel. At 6:48:36 PM, two vehicles arrived in the area and abruptly stopped approximately 100 feet east of the home. At 6:48:45 PM, Victim 2 emerged from the first vehicle and ran toward the home. Defendant emerged from the second vehicle and pursued Victim 2 on foot. At 6:48:50 PM, Victim 1 tossed the shovel onto the ground, where it remained throughout the incident, and stepped back toward the front door of the home. At 6:48:52 PM, Victim 2 reached the front of the home but slipped on the ground before he could reach the front door. At 6:48:55 PM, Defendant caught up to Victim 2, jumped on top of Victim 2, and engaged in a brief struggle with Victim 2 on the ground in front of the home. At 6:48:57 PM, Defendant rolled off Victim 2 and onto the ground while Defendant continued efforts to grasp onto Victim 2. At 6:49:01 PM, Victim 1 approached Victim 2 and reached down, appearing to separate Victim 2 from Defendant and help Victim 2 off the ground. At 6:49:04 PM, Victim 1 and Victim 2 ran to the front door of the home, out of camera-view at 6:49:06 PM. At 6:49:08 PM, Defendant got off the ground and stood several feet from the front door of the home, just as additional ICE vehicles were arriving on 24th Ave. approximately 100 feet east of the home. At 6:49:09 PM, as Defendant faced the front door of the home, Defendant raised both of his arms straight out in front of him, pointing toward the front door. Defendant's movements between 6:49:09 PM and 6:49:10 PM are consistent with Defendant firing a gun at the front door of the home. Defendant then stepped back and spoke to an arriving ICE agent.
Reports of Shooting, Statement of Victim 3, and Immediate Scene Response
Immediately after this incident, MPD received multiple reports of a single gunshot occurring in front of XXX 24th Ave. N. One of those reports was from “ShotSpotter," an acoustic gunshot detection system which utilizes a network of sensors installed in the city of Minneapolis to detect, locate, and alert MPD to gunfire in real-time. ShotSpotter reported that a single round was fired in front of XXX 24th Ave. N. at precisely 6:49:09 PM.
A separate report of the shooting came from a 911 caller who was inside the home at XXX 24th Ave. N. at the time of the gunshot. This individual, identified as Victim 3, reported that there were four adults and two children inside the home when an ICE agent shot into it. The adults in the residence referenced by Victim 3
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<p class="g-doc-text" id="page-4-text">27-CR-26-12537
Filed in District Court
were identified as Victims 1, 2, 3, and 4. Victim 3 explained that Victim 2 was chased to the home by 2026 and that, once Victim 2 got into the home, ICE shot at them. Victim 3 emphasized that ICE shot at all of them and hit Victim 1 in the leg. Victim 3 further reported to the 911 dispatcher that ICE remained outside the home and was trying to gain entry.
At approximately 6:50 PM, MPD officers and paramedics began responding to the scene, where they encountered numerous ICE agents surrounding the home. ICE agents deployed tear gas, entered the home, and took Victims 1, 2, 3, and 4 into custody. Almost an hour later, at 7:48 PM, paramedics were allowed access to Victim 1 and transported him to North Memorial Hospital, where he was treated for a gunshot wound to the leg.
While on the scene, MPD contacted the BCA, reported that an ICE agent was involved in a shooting, and requested the BCA's assistance with the investigation. BCA investigators deployed to the scene and to North Memorial Hospital.
Interview of ICE Agent 1
At the scene, BCA investigators encountered Federal Bureau of Investigation ("FBI") agents who agreed to conduct a joint investigation into the shooting, and, at 8:36 PM, personnel from the two agencies conducted a joint video-recorded interview with an ICE agent (hereinafter “ICE Agent 1").
ICE Agent 1 stated that he, Defendant, and two other agents (hereinafter “ICE Agent 2" and "ICE Agent 3") pursued Victim 2 for 7-10 minutes on the highways and streets of Minneapolis to XXX 24th Ave. N. ICE Agent 1 stated that the pursuit began after ICE "ran a background information on somebody and ... made sure that the person was apprehendable." ICE Agent 1 stated that Defendant was the initial pursuer of the vehicle and that Defendant arrived at the victims' home before ICE Agent 1 arrived. ICE Agent 1 stated that the shooting occurred just before ICE Agent 1 arrived. Upon arrival, ICE Agent 1 said that he had a verbal exchange with Defendant. ICE Agent 1 described the exchange: “[Defendant] had told us that the two individuals came outside with the shovel and the broom had smacked him with it, got him on the ground, hit him with it, and of course, [Defendant] shot one round. He wasn't sure if he hit anybody. They had already shut the doors on us." ICE Agent 1 explained that the occupants of the home refused to exit, so ICE breached the house. ICE Agent 1 provided the names and cellphone numbers of ten ICE agents who were part of his team, and the list included the names of Defendant, ICE Agent 1, ICE Agent 2, and ICE Agent 3. ICE Agent 1 unambiguously identified Defendant as the shooter.
Soon after conducting the interview of ICE Agent 1, FBI agents at the scene informed the BCA that they had been directed to cease working with the BCA and that no further interviews would be conducted at the scene. At that point, federal authorities stymied all further efforts by the BCA to interview additional ICE agents or Defendant himself. To date, federal authorities have prevented any further interviews of involved federal agents.
Statement of Victim 1 and Documentation of Victim 1's Gunshot Wound
At 8:26 PM on January 14, 2026, BCA investigators arrived at North Memorial Hospital, where they spoke to Victim 1. Victim 1 explained that he lived at XXX 24th Ave. N. with Victims 2, 3, and 4, and two young children. Prior to the shooting, Victim 1 was at home and received a call from Victim 2. Victim 1 stated that Victim 2 reported to him that, while Victim 2 was working for DoorDash, he encountered ICE agents, who began pursuing him in an unmarked pickup truck. Victim 1 stated that, out of fear, Victim 2 did not stop his vehicle and attempted to evade the agents and get back to his home. Victim 1 stated that, as Victim 2 approached the home, Victim 1 exited the home and witnessed Victim 2's arrival. Victim 1 saw Victim 2 exit his vehicle and run toward the home, followed by a single ICE agent. Victim 1 saw the ICE agent catch
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<p class="g-doc-text" id="page-5-text">27-CR-26-12537
Filed in District Court State
5/18/2026
Victim 2 and struggle with Victim 2. Victim 1 intervened by pulling Victim 2 away from the agent, staffď Minota 2 broke free. The agent attempted to grab Victim 2 again. Victim 1 offered that, at that point, Victim 1 swung a broom at the agent, but Victim 1 did not strike the agent. Victim 1 and Victim 2 then ran into the home. Victim 1 stated that, as he stood inside the home, behind the front door, and while attempting to close and lock the door, Victim 1 heard a loud gunshot and was shot in his right leg. Victim 1 and Victim 2 then fled upstairs and attempted to barricade themselves inside the home, at which point ICE agents broke windows, deployed pepper spray inside the home, and took him and the other occupants of the home into custody.
While speaking to Victim 1 at the hospital, BCA investigators photographed an acute gunshot wound to Victim 1's right leg and obtained Victim 1's medical records. They observed and documented with a ruler that, in a standing position, Victim 1's gunshot wound was 32 inches from the ground.
Statement of Victim 2
BCA investigators spoke to Victim 2, who explained that, prior to the shooting, Victim 2 was delivering meals for DoorDash and observed a vehicle pull up next to him. Based on the appearances of the occupants of the other vehicle, Victim 2 surmised that they were associated with ICE. Those occupants pointed at Victim 2 from inside their vehicle and maneuvered their vehicle to try to block him. Victim 2 explained that he feared for his life, so he drove away. The ICE agents pursued Victim 2 for what he estimated to be 25 minutes. During the pursuit, Victim 2 called Victim 1 and decided to drive home. Once Victim 2 arrived on 24th Ave., Victim 2 exited his car and ran toward his house. ICE agents stopped behind Victim 2's vehicle, and one agent ran after him. At that point, Victim 2 saw Victim 1, Victim 3, and Victim 4 standing in the foyer inside the front door of the home.
Victim 2 stated that he slipped on the ice in front of his home, and the ICE agent tackled Victim 2, causing them both to fall to the ground. Victim 2 stated that he did not punch or assault the agent and that Victim 2 was just trying to get away from him. Victim 2 was able to break free, stand up, and grab a broom. Victim 2 held the broom briefly like a baseball bat facing the agent, but Victim 2 did not swing it and threw it down on the ground. Victim 2 and Victim 1 then ran into the home. Once inside, Victim 2 observed Victims 3 and 4 begin to run up the stairs and saw Victim 1 standing behind the front door, locking the door. At that moment, Victim 2 heard a single gunshot coming from outside the home and observed that Victim 1 was shot in the leg. The four victims then ran upstairs and barricaded themselves in a room. Soon after, ICE agents threw tear gas into the home, entered, and took everyone into custody.
Statement of Victim 4
BCA investigators spoke to Victim 4, who explained that, prior to the shooting, Victim 2 called to explain to Victims 1, 3, and 4 that ICE was chasing him and that he was coming home. In response, they called 911 and went down to the front of their home to wait for Victim 2 to arrive. Victim 2 arrived and ran toward the home, chased by a single ICE agent. Victim 4 saw that the ICE agent grabbed Victim 2, and Victim 1 went out to separate Victim 2 from the ICE agent. Victim 2 was able to get away from the ICE agent, and Victim 1 and Victim 2 ran back inside the home. At that moment, Victim 3 and Victim 4 were standing on the staircase within sight of the front door. Victim 1 was in the process of closing and locking the door when Victim 4 heard one gunshot. They all ran upstairs, and Victim 4 observed that Victim 1 was shot in the right leg. The victims immediately called 911 again and remained in the house until ICE shot tear gas into the house, breached the door, and arrested everyone.
Statement of Defendant at Cambridge Medical Center
BCA investigators learned that, on the night of the shooting, Defendant traveled by private vehicle to the
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<p class="g-doc-text" id="page-6-text">27-CR-26-12537
Filed in District Court
5/18/2026
Cambridge Medical Center in Cambridge, MN, where at 8:44 PM Defendant underwent a meditate of Minnesota examination, which included radiographic imaging. At that time, Defendant claimed that, while in the process of trying to detain a suspect, “other persons" came and started hitting Defendant with a broom and a snow shovel. Defendant claimed that these people were trying to hit him in the head, and that Defendant was hit twice in the head with the shovel, but that he did a "good job” of blocking the blows by covering his head.
While Defendant's account of events mirrored the account he provided to ICE Agent 1 at the scene, this account is not corroborated by the video of the incident or the accounts of Victims 1, 2, 3, or 4. Medical records document that Defendant suffered no demonstrable trauma to his body except for an abrasion to his left hand at the base of his thumb. The abrasion was cleaned off, and Defendant was discharged at 10:52 PM.
Collection and Review of Physical Evidence
Forensic scientists from the BCA responded to XXX 24th Ave. N to document the scene and collect physical evidence. They collected a shovel from the front yard, where the video from the city camera revealed Victim 1 had thrown it prior to Defendant arriving, a 9mm caliber discharged cartridge casing from the ground outside the front entrance of the home, a broom from the front step outside the entrance of the home, and another broom in the foyer. They observed a single bullet hole in the front door of the home. The hole was approximately 36.5 inches from the cement slab outside the residence and approximately 28 inches from the floor of the foyer inside the residence. Across the foyer from the front door, forensic scientists located additional defects in the residence that were consistent with a projectile passing through the front door, across the foyer, and then through the foyer wall, a closet, and a bedroom wall, where the projectile came to a rest. A single projectile was located inside the bedroom wall. The projectile was examined and determined to be consistent with being a jacketed hollow-point bullet fired by a 9mm caliber firearm. Utilizing physical and photographic evidence, forensic scientists conducted a trajectory analysis, finding that "the shot that fired the projectile originated outside of the duplex building, south of the front main door and traveled approximately south to north at a downward angle."
Defendant's Statement to FBI
BCA investigators learned that, following the incident, Defendant spoke to FBI agents about the incident. A summary of Defendant's statement to the FBI was included in an affidavit signed by an FBI agent on January 16, 2026. In the affidavit, Defendant (identified as ERO #1 therein) reported that he was driving an unmarked vehicle with another agent in his passenger seat. They observed a Ford Focus, ran its license plate through ICE databases, and concluded that the registered owner of the vehicle was not a United States citizen. Defendant attempted a traffic stop, but the vehicle fled. Defendant stated that he engaged in a high-speed pursuit of the vehicle with his lights and sirens activated for 15-20 minutes until the pursuit concluded with the vehicle's driver, Victim 2, coming to a stop on 24th Ave. N and running toward his home. Defendant stated that he exited his vehicle and chased Victim 2 on foot. Defendant stated that he saw a separate male, Victim 1, standing on the porch of the home and heard him yelling at Victim 2 to run faster. Victim 2 then slipped and fell on the ground, and Defendant grabbed Victim 2 to attempt to detain him.
According to the FBI affidavit, Defendant claimed to the FBI that, at that point, Victim 1 grabbed a broom and began striking him in the face and then a third male approached him with a snow shovel and began striking him with the shovel. Defendant claimed that, while being assaulted with a broom and a shovel by two assailants, he continued to tussle with Victim 2. According to the FBI affidavit, Defendant reported that he struggled with the three men “for about three minutes, was exhausted, alone, on the ground, and in fear of his safety." Victim 2 then freed himself and, according to Defendant, gave him an “angry scowl." Victim 1 then passed the broom to Victim 2, and, according to Defendant's account in the FBI affidavit, Victim 2
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<p class="g-doc-text" id="page-7-text">27-CR-26-12537
Filed in District Court
5/18/2026
struck Defendant repeatedly in the face or head with the broom while Defendant was lying on his the ground. Defendant claimed that he tried blocking the blows with his left hand while drawing his service pistol with his right hand. He then pulled out his service pistol and pointed it in the direction of the three assailants. According to the FBI affidavit, Defendant claimed that, once Defendant pointed his pistol at the three assailants, they began running toward the front door of the home. Before they could enter the home, Defendant claimed, he fired one shot at them, unsure of whether he struck anyone. According to Defendant, after he fired the shot, the assailants ran inside and closed the front door.
Defendant's account to the FBI resembles his account to ICE Agent 1 and his account at the Cambridge Hospital. However, his account is contradicted by the video of the incident, the accounts of Victims 1, 2, 3, and 4, and the physical evidence.
Initiation and Abandonment of Federal Prosecution of Victim 1 and Victim 2
On January 16, 2026, the United States Attorney's Office for the District of Minnesota filed the FBI affidavit which summarized Defendant's claims in the United States District Court for the District of Minnesota in support of federal felony assault charges against Victim 1 and Victim 2. Following several court appearances in the criminal proceedings against Victim 1 and Victim 2, on February 11, 2026, United States Attorney Daniel N. Rosen moved to dismiss all charges against Victim 1 and Victim 2, acknowledging that "[n]ewly discovered evidence is materially inconsistent with the allegations in the Complaint Affidavit," and stating that "dismissal with prejudice will serve the interests of justice." On February 13, 2026, District Court Judge Paul A. Magnuson dismissed those charges against Victim 1 and Victim 2.
Further investigation revealed that, at the time of the shooting, Victim 1 and Victim 2 were residing in Minnesota lawfully, having been granted "Temporary Protected Status” by the United States Department of Homeland Security.
Statements of Victims to FBI
BCA investigators are aware that FBI agents spoke to multiple other witnesses to the shooting on January 14, 2026, and conducted separate interviews with Victims 1, 2, 3, and 4. The aforementioned FBI affidavit, which was filed on January 16, 2026, included summaries of the victims' statements to the FBI. To the extent that the content of the victims' statements can be gleaned from the affidavit, Victims 1, 2, 3, and 4 separately provided statements to the FBI which report that all of the victims were at the threshold of their home when Defendant attempted to apprehend Victim 2 but that they were inside the home behind the front door when Defendant shot at them through the door. As to the particulars of their statements, despite repeated and standing requests from the BCA, the federal authorities have refused to provide the BCA access to any record or report of the interviews and to all other evidence exclusively in the possession of the federal government.
A warrant for Defendant's arrest is necessary because his whereabouts are unknown and there is a substantial likelihood that Defendant will not respond to a summons.
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