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Case 1:21-mj-00038-MEH Document 1 Filed 03/10/21 USDC Colorado Page 1 of 1

AO 91 (Rev. 11/11) Criminal Complaint


for the
__________ of Colorado
District of __________

United States of America )

v. )
) Case No. 21-mj-00038-MEH

I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of March 9th, 2021 in the county of Denver in the
District of Colorado , the defendant(s) violated:

Code Section Offense Description

Title 49, United States Code, Interference with Flight Crew Members and Attendants
Section 46504

This criminal complaint is based on these facts:

See Affidavit attached hereto and hereby incorporated by reference.

✔ Continued on the attached sheet.


s/Martin H. Daniell III

Complainant’s signature

Martin H. Daniell III, SA, FBI

Printed name and title

Sworn to before me and signed in my presence. [ submitted, attested to, and acknowledged by reliable electronic means.

Date: 03/10/2021
Judge’s signature

City and state:

Printed name and title
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I, Martin H. Daniell III, Special Agent with the Federal Bureau of Investigation,

Department of Justice, being duly sworn, deposes and states under penalty of perjury the

following is true to the best of my information, knowledge, and belief.


1. Your affiant is a Special Agent with the Federal Bureau of Investigation (FBI)

and has been so for over twenty-one years. Your affiant is currently assigned as

the FBI Airport Liaison Agent at Denver International Airport (DEN) and

investigates violations of federal law that occur at the airport, as well as crimes

that occur in the Special Aircraft Jurisdiction of the United States and incidents

involving the laser illumination of aircraft in flight.


2. On March 9, 2021, at approximately 5:00 p.m., your affiant was advised of a

disturbance aboard Alaska Airlines Flight 1474 that occurred while the flight was

in route from Seattle-Tacoma International Airport (SEA) to Denver, Colorado

(DEN). Your affiant responded to Gate C-39 at Denver International Airport

where he spoke to officers from the Denver Police Department, reviewed

statements written by flight crew members and passenger witnesses. Your affiant

also conducted follow-up interviews. This investigation revealed the following:

3. During the flight from Seattle to Denver, a female Alaska Airline flight attendant,

herein identified by the initials C.E., noticed that twenty-four year old male

passenger Landon Perry Grier was not wearing a face covering, as required by

airline policy due to the COVID-19 pandemic. She approached Grier and asked

him approximately eight to ten times to put his face covering on. Grier was

seated next to the window and appeared to be attempting to sleep. Grier ignored
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C.E. and then began to push and swat her hand away as she tried to gently tap

his shoulder to get his attention. While doing this, he made contact with her right

forearm approximately three times. He subsequently struck her arm two to three

times in an attempt to aggressively dismiss her. During this incident, his strikes

resulted in actual physical contact with flight attendant C.E. When interviewed,

C.E. stated that Grier disrupted the entire safety of the aircraft by refusing to

wear his face covering.

4. Later in the flight, two other Alaska Airlines female flight attendants, herein

identified by the initials K.F. and K.K., responded to a flight attendant call button

that had been pressed. A passenger reported to flight attendant K.K. that

passenger Grier was urinating in his seat area and K.K. observed him doing this

and told him to sit down. Flight attendant K.F. then observed passenger Grier

seated in his seat with his penis out of his pants and she told him to put his penis

back in his pants. He responded, “I have to pee.” Several of the passengers

seated around passenger Grier were then reseated and the Captain was called

to notify him of what had happened. Flight attendant K.F. stated passenger

Grier’s actions delayed her preparation of the aircraft cabin for landing for

approximately ten minutes, endangering the safety of the passengers. Flight

attendant K.K. said she was unable to clean up the cabin because her attention

was on passenger Grier instead of her assigned duties. Moreover, the flight

experienced a mechanical issue that caused the flight crew to make an

emergency landing at DIA.

5. Forty-eight year old male M.S. was the Pilot in Command (Captain) of Flight

1474. He advised he and the first officer had declared an emergency to air traffic

control due to a maintenance issue onboard their aircraft and their landing

briefing was interrupted by the call from K.F. who told him about passenger
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Grier’s behavior. He stated the passenger disruption occurred during a high

work load environment while they were descending over the mountains in

turbulent conditions. The disruption caused the pilot crew to divert attention from

their emergency landing preparation.

6. Your affiant also spoke with a female passenger identified herein by the initials

J.C. She said passenger Grier first got her attention when he swatted at the flight

attendant when she asked him to put his mask on. She advised later he stood

up, took out his penis, and began peeing which wet a paper bag she had with


7. After obtaining these statements, I also met with Grier. After being advised of

his Miranda rights, he agreed to speak to your affiant without a lawyer present.

During the subsequent conversation, passenger Grier advised he was returning

from Alaska where he had been working in a gold mine. Prior to leaving Alaska,

he had one beer and then had three to four beers and “a couple of shots” before

boarding the plane in Seattle. He also took an over-the-counter pain reliever

because he had body aches from working. He said he fell asleep on the plane

and awoke to being yelled at by the flight attendants who told him he was

peeing. He stated he had no recollection of hitting the flight attendant and didn’t

know if he was peeing.

8. The incident as described herein occurred while Alaska Airlines Flight 1474 was

operating in the special aircraft jurisdiction of the United States.


Based upon the above information, probable cause exists to believe Landon Perry Grier

has violated Title 49, United States Code, Section 46504 - Interference with Flight Crew

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Members and Attendants. I declare under the penalty of perjury the foregoing information is

true to the best of my knowledge.

s/Martin H. Daniell III

Special Agent
Federal Bureau of Investigation

WK day of
Submitted, sworn to, and acknowledged by reliable electronic means on ____
March, 2021.

United States Magistrate Judge

Affidavit reviewed and submitted by Bradley W. Giles, Assistant United States Attorney.
Case 1:21-mj-00038-MEH Document 1-2 Filed 03/10/21 USDC Colorado Page 1 of 1



OFFENSE(S): 49 U.S.C. § 46504, Interference with Flight Crew Members and Attendants

OFFENSE: Denver, Colorado

PENALTY: NMT 20 years imprisonment, NMT $250,000 fine or both; NMT 3 years
supervised release; $100 Special Assessment

AGENT: Martin H. Daniell III, SA, FBI

AUTHORIZED Bradley W. Giles

BY: Assistant U.S. Attorney


__ will seek detention in this case based on 18 U.S.C. § 3142(f)(1)

X The statutory presumption of detention is not applicable to this defendant.