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Pennsylvania Bar Association © 2002
) Case No. FECR-MT- 7834569 Plaintiff, ) ) vs. ) ) DANNIE DAWSON, ) TRIAL INFORMATION ) Defendant. ) Olivia Brooks, Assistant Leon County Attorney, as Prosecuting Attorney of Leon County, State of Iowa, accuses Dannie Dawson of the following crime: COUNT I Arson in the Second Degree , in violation of Sections 712.1 and 712.3, of the Iowa Code, in that Dannie Dawson, in the County of Leon and the State of Iowa on or about March 5, 2024, did unlawfully, knowingly, and intentionally cause a fire intending to destroy or damage the Paul and Frances Lubben Natural Sciences Building on the campus of Tabard University, a class C felony. A TRUE INFORMATION Olivia Brooks Olivia Brooks Assistant Leon County Attorney 7421 Douglas Avenue Hinz, Iowa (515) 276- 6222 APPROVAL AND ORDER FOR ARRAIGNMENT This Information and the Minutes of Evidence accompanying it have been examined by me and found to contain sufficient evidence, if unexplained, to warrant a conviction by a trial jury; the filing of this Information is approved by me on this 13 th day of August 2024. APPROVAL AND ORDER FOR ARRAIGNMENT Place: Leon County District Court Date: August 1 5 , 20 24 Time: 9:00 a.m. ___ Defendant is released on personal recognizance ___ Bond is set in the amount of $______. ___ Bond may be unsecured ___ Bond must be cash or secured in the amount of the bond ___ 10% cash may be posted ___ Clerk of Court shall issue a summons for Defendant to appear. ___ Clerk of Court shall issue an arrest warrant.
) Case No. FECR-MT- 7834569 ) ) Plaintiffs, ) ) vs. ) ) DANNIE DAWSON, ) ) Defendant. ) STIPULATIONS OF THE PARTIES
1 My name is Bobby Bunson. I live at 2004 Cornell Avenue in Hinz, Iowa. Hinz is in Leon 2 County. I’m an Art major at Tabard University, and ever since I can remember, I’ve dreamed of 3 making a name for myself in the art world. 4 Life at The Maverick—that’s what we call our house on Cornell Avenue, a nod to Tom 5 Cruise in Top Gun —has been awesome (it better be given how much we pay in rent). Unlike many 6 of my roommates, my parents don’t pay for my rent, my groceries, or anything else. I’ve always 7 had to find my own way. Growing up, I couldn’t afford art supplies, so I raided the trash cans in 8 the art classroom for leftover brushes and old paint. I’ve always been scrappy. That’s probably 9 why I’ve learned to fight so hard for every opportunity. 10 I always thought I’d win the full-ride scholarship that Leon County awards to the top high 11 school senior each year. I thought it would solve all my problems. At Beatty Wiese Academy, I 12 was known as one of the most promising art students the school had ever seen—on top of my near 13 perfect high school grades and science bowl championship. But apparently nobody there had heard 14 of Dannie Dawson—the top student at Leon Central High School. Dannie won the scholarship fair 15 and square. I took second place, a $10,000 award that barely covered tuition for my first semester. 16 I was obviously naïve to count on the full-ride scholarship, but by the time I knew I had only 17 finished second place it was too late to apply to other colleges. 18 I’ve never told Dannie this but losing that scholarship made my life a lot harder. Even so, 19 I’ve pushed through. I’m still in school, juggling classes and a part-time job at the Olson Museum, 20 which showcases some of the best art in the northeastern part of Leon County. Someday, I hope 21 my own work hangs there, inspiring other students the way that collection inspires me. Right now, 22 though, the only thing I am hanging up is coats at the museum’s coat check. Despite everything, 23 Dannie and I have become friends over the past three years. I think it’s because each of us has 24 what the other lacks—Dannie’s brilliant with math and science, while I’m all about creativity and 25 imagination. 26 Dannie is very hardworking. I think that it comes from Dannie’s upbringing. Dannie’s 27 parents are both prominent members of society. One parent is Elliott Dawson, the former Chief 28 Judge of Iowa’s 9th^ Judicial District and now television star. (I’ve seen the show. It is wildly 29 popular, but it is not my taste. I think there’s too much yelling.) The other parent, Luca Dawson, 30 is known internationally for research towards a cure for some rare birth defect. I can’t remember
31 what it is called. With parents like that, expectations were sky-high. Honestly, it’s one part of 32 Dannie’s life I’ve never envied. Growing up under that kind of pressure meant nothing short of 33 perfection was ever good enough. I’ve always felt that many of Dannie’s choices weren’t about 34 pursuing Dannie’s interests, but about living up to what the parents expected. Sure, Dannie’s 35 brilliant; but if not for constantly trying to please the parents, I suspect Dannie would be taking a 36 very different course in life. 37 I think this because Dannie’s always asking me about my painting and music. Even though 38 Dannie pretends to hate my taste in bands, they still show up to every open mic night and sit 39 through my whole set. And Dannie once asked me to do an entire painting of a molecule they were 40 studying in class—not because they needed it, but because they thought it would “make chemistry 41 feel more beautiful.” So, yeah, I think Dannie is curious about the creative world, even if Dannie 42 acts differently. 43 I play classical guitar as a hobby, and during our sophomore year, Dannie hinted about 44 wanting to give it a try. I figured, why not—I’d love to share what I know. Turns out, that was a 45 mistake! Dannie had the theory down almost instantly—within a day, Dannie could point to any 46 note on the fretboard and talk through every scale like a pro. But when it came to actually playing? 47 Total chaos. Dannie’s fingers just wouldn’t cooperate, and eventually Dannie snapped and blew 48 up. At first, Dannie felt like a failure. Then came the blame—aimed at me, the guitar maker, even 49 the guitar itself. I think Dannie even fired off a nasty email to the manufacturer. We stuck it out 50 for three weeks, and while I tease Dannie that those were the longest and worst three weeks of my 51 life, truth is, I felt bad watching the struggle, especially when the guitar came so easily to me. 52 As a housemate, Dannie is spotless—seriously, the main the reason The Maverick doesn’t 53 look like the typical college crash pad. Dannie cleans constantly and never once complains about 54 the mess the rest of us make. Dannie is also incredibly considerate; if I need quiet to study or work 55 on an art piece, Dannie just knows. Aside from those three chaotic weeks when Dannie tried to 56 become a guitarist, maybe the perfect roommate. That more than makes up for our other roommate, 57 Reuben McAlister. Reuben is always leaving bits of sandwiches everywhere and stinks up the 58 house with his homemade sauerkraut. 59 By junior year, things were going great for Dannie and I—both as housemates and as 60 students—so we decided to shake things up and take a class outside our comfort zones and in each 61 other’s area of study. I signed up for calculus (which, to me, felt like ancient torture), and Dannie
93 At one point, they grabbed an old tennis racket and smashed a hole through their bedroom 94 wall. The place looked like a tornado had hit it. At the time, I chalked it up to anger and shock— 95 Dannie had never touched drugs or alcohol and used to call them “entertainment for the weak- 96 minded.” 97 I wanted to help, but nothing I said made a difference. Dannie just kept shouting Professor 98 Whitmore’s name, louder and louder, saying they wanted him to feel the same pain he’d caused. 99 Dannie even said they wished he would die and burn in Hades. Looking back, it does seem like 100 Dannie was fixated on the idea of fire, flames, and burning. Eventually, when it became obvious I 101 couldn’t calm Dannie down, the rest of us in the house quietly packed up and stayed with friends 102 for the night, hoping Dannie would cool off. 103 When I got home the next day, March 3, the kitchen table was covered with scattered pens, 104 sheets of paper, and a few books—one of them about using hot plates. On top of the pile was a 105 short poem Dannie had written and signed. I wasn’t sure what to make of it. It read more like a 106 threat aimed at Professor Whitmore than anything poetic. Perhaps the B- was Professor Whitmore 107 giving Dannie some grace. 108 Dannie stayed holed up in the room that entire day and the next, skipping all scheduled 109 classes and falling behind on schoolwork. When Dannie finally went back to campus on Tuesday, 110 March 5, Dannie spent more than twelve hours on campus. I know because I saw Dannie leave at 111 6:00 a.m. and not come home until around 8:00 p.m. Dannie still seemed a little upset, but that 112 evening was the first time we’d actually talked since the meltdown on March 2. 113 We ended up sitting at the kitchen table for a couple of hours, reading and working on 114 assignments together—our usual routine. For the first time in days, Dannie felt almost like their 115 old self again, and I remember thinking maybe things were finally turning around. 116 At 10:00 p.m. that night, we settled in to watch the nightly news, like we always did. Dannie 117 was chatting more than usual, even cracking a few jokes, though I could still see some of that 118 tension under the surface. Then, the anchor mentioned a fire burning over at Tabard University in 119 the Paul and Frances Lubben Natural Sciences Building. Dannie immediately sat up straight, eyes 120 locked on the screen. The reporter said the fire was still active, the cause unknown, but thankfully 121 no one was believed to be inside and nobody had been hurt. 122 Dannie kept repeating that they couldn’t believe it. Dannie said that they’d just been in that 123 building right before coming home. After the story about the fire, Dannie didn’t move from the
124 TV room for the rest of the night. Dannie said they wanted to stay up in case there was a special 125 news update. Dannie later mentioned they’d signed up for extra streaming news services—CNN, 126 NBC, CBS—just to see if the fire hit national headlines. I thought it was a little strange, but I didn’t 127 press. 128 When the 6:00 a.m. news came and went without another mention of the fire, Dannie still 129 stayed glued to the screen, missing class completely. I didn’t have any classes that Wednesday, so 130 I stayed. Part of me understood why—Dannie was clearly shaken. Another part of me just couldn’t 131 imagine throwing away a day like that. Every hour of school, every shift at the Olson Museum, 132 every late night with my sketchpad feels like it matters. I’ve got big dreams—galleries, awards, 133 maybe even changing how people see art—and to get there, I can’t afford to waste opportunities. 134 It wasn’t until the noon broadcast that we finally heard more: the fire department said that 135 the fire was first reported at about 8:30 p.m. by a student campus safety officer named Willy 136 Bannister. They estimated it started around 7:45 p.m. The cause was supposedly a hot plate that 137 was left on in a lab on the southeast corner of the second floor. The fire department was going to 138 investigate the possibility of it being arson. They said that they wanted to question some students 139 about it, but they wouldn’t release any names. 140 When we heard that update, Dannie’s mood shifted fast. Dannie started pacing, looking 141 panicked, saying they just knew the investigators would want to talk to them. Dannie said that 142 Dannie, C.J. Schultz, and Fenix Blake are going to be suspected since they were the last ones in 143 that lab. Dannie kept asking me, over and over, “What do I do? What do I do?” and saying that 144 Professor Colfax, the chair of the Chemistry Department, was married to Professor Whitmore, and 145 that the fire department would suspect Dannie because Dannie had sent some email or something 146 to Professor Whitmore. It was intense. Dannie even told me that if Dannie was blamed, it was only 147 because “Reuben did not want to give up the commencement speech.” 148 That comment caught me off guard, but I knew what Dannie meant. Everyone knows that 149 Tabard lets the top-ranked student speak briefly at graduation, a small reward for their success, 150 and Dannie has been #1 the entire time—but obviously you can’t give the speech if you get kicked 151 out for burning down a building. Reuben McAlister has always been right behind Dannie, but I am 152 not sure Reuben would be a great public speaker. I doubt Reuben would go as far to torch a building 153 to get a three-minute speaking opportunity; that seems ridiculous. Plus, I’m not sure that Reuben
1 My name’s C.J. Schultz. I live at 405 Critelli Circle in Hinz, Iowa. Most people at Tabard 2 know me for one thing: I’m the champ who somehow won the campus chili cook-off two years in 3 a row. I don’t even remember entering the second time—someone just handed me an apron and 4 said, “Defend your title.” I guess word got around, because now professors call me “Chef CJ,” 5 even in chemistry lab. I’ve been told my chili could probably strip paint off the walls, which is 6 ironic because now I’m here talking about an actual fire. 7 I was a junior studying chemistry at Tabard University when the fire happened. I had a 8 class with Dannie Dawson that spring, and over the years we’d had a few other courses together. 9 We weren’t exactly friends—never hung out outside class or anything—but I knew who Dannie 10 was. 11 Everybody knew Dannie’s reputation. My advisor even told me I was third in the whole 12 graduating class, right behind Dannie and Reuben McAlister. Pretty hard to beat someone who 13 never gets below an A; Dannie’s academic success is mind-boggling. Even with that one B-minus 14 in Dannie’s poetry class, they’re still way ahead of me. I was holding a 3. 87 GPA, which is solid 15 enough for Class Rank #3, but let’s be real—I wasn’t catching up to Dannie or Reuben anytime 16 soon. Everyone knew that whoever was #1 in the class got to speak at commencement, and 17 everyone figured it was always going to be Dannie. 18 I actually talked to Dannie for one of the first times ever on the night of March 5, 2024. I 19 was in the lab that evening, trying to finish up one of our weekly chemistry assignments, which 20 was due by 5:00 p.m. on Wednesday, March 6th. Normally, we do these labs Monday mornings 21 from 10 a.m. to noon, but if you miss it, you can come into Lab 2A anytime and do it yourself— 22 as long as the assignment was submitted before the deadline. However, if you did the lab 23 assignment on your own time, the Teaching Assistant would not be present to answer questions or 24 bail you out if you mess up. The weekend before the Monday morning lab, I had been in Ames 25 volunteering for the Middle School Science Bowl competition. I did not get back to Leon until late 26 on March 3rd, and I accidentally slept through that week’s lab. Not my proudest moment, but hey, 27 that’s what makeup sessions are for. 28 I went to the lab on Tuesday night on March 5th^ to do the makeup. I had hoped to get started 29 by around 4:30 p.m. I’m not athletic enough to play, but I work part-time as a referee for the 30 intramural battle ball league on campus, and that day’s game went into overtime. When I finally
31 arrived around 5:15 p.m., Fenix Blake was already working at lab station six. I got set up at lab 32 station one. Dannie Dawson showed up a little later and grabbed station seven. Around the time I 33 showed up, I saw Reuben McAlister, very briefly, walking down the hallway on the first floor. At 34 least, I think it was him. I only saw his backside. Whoever it was, they were carrying flyers that 35 had what I think was a big pencil on them. 36 We were all just trying to get through it…well, at least I was. The assignment wasn’t 37 complicated, just long and kind of boring. Each of us had our own hot plate, microscope, a bunch 38 of flasks, and petri dishes. I joked once that if you stacked all that gear together, it looked less like 39 a science experiment and more like a high school band setting up for a concert. I can play a mean 40 triangle if chemistry doesn’t work out. For this assignment, we had to do tests on a bunch of 41 different chemical solutions that smelled awful. The whole point was to heat each substance to 42 certain temperatures—up to 4 50 degrees—then dump it into a petri dish and check under the 43 microscope to see what tiny organisms survived. 44 There were twenty different substances we had to test. Twenty. That’s a lot of heating, 45 pouring, and staring into a microscope. By the end, everything started looking the same to me. I’ll 46 admit, I might not have been triple-checking every little detail—I was just trying to wrap it up and 47 get out of there. 48 While we were working, we were chatting a lot. I’m good friends with Fenix, and Fenix 49 knows Dannie about the same as I do—not super close, but enough to joke around. We were having 50 a decent time that night, just trying to crank through the assignment. 51 Students can use the labs 24/7 if they want, but the building officially “closes” at 6:00 p.m. 52 No classes after that. After 6:00, you’ve got to scan your student ID to get in and out—there’s a 53 scanner on both sides of every door. The individual classrooms stay unlocked, though, so once 54 you’re in, you can go wherever. Technically, each person is supposed to scan every time they enter 55 or leave, even if someone holds the door. That’s the rule, and they say it’s an Honor Code violation 56 if you skip it. But in practice? Most people don’t bother to scan out after 6:00 p.m. I mean, 57 especially after dark, no one is watching the logs. 58 Dannie is an ardent rule follower and was definitely going to be sure to scan in right at 59 6:00. Of course, I followed the good example and at 6:00, the three of us—Fenix, Dannie, and 60 me—went out to scan our cards. Fenix and Dannie went right back in to keep working, but I hung
92 natural gas until they cut the power. That’s why they installed a master power shutoff for each 93 laboratory. 94 Fenix headed toward the West Parking Lot, so they used the door at the far end of the 95 building. Dannie and I were both parked in the South Parking Lot, so we were going to exit the 96 East door. Upon exiting the lab, we stood in the hallway for a few minutes while we finished our 97 conversation. 98 When we split up, Dannie and I walked out of the door that was right there—we both 99 scanned out. Right after we stepped outside, Dannie said they needed to run back in and use the 100 bathroom quick. I said I’d hang out at the top of the steps and have another smoke. Dannie called 101 it a filthy habit, told me to quit or try the patch, then headed back inside. 102 Dannie was gone for a while. Eventually, Dannie came running back out, apologizing for 103 keeping me waiting. I said it was no big deal—I was still working on my cigarette. The only thing 104 that struck me as a little odd was when Dannie came back through the glass door. From where I 105 was standing, I could see the inside of the hall. The bathrooms are on the right side, but Dannie 106 came from the left, as if Dannie had come from the lab area instead. It wasn’t a huge thing at the 107 time, just… noticeable. 108 We headed down the steps into the East Parking Lot and turned the corner toward the 109 South. That’s when I noticed Dannie was sweating a bit and seemed kind of out of breath. At first, 110 I just figured they’d run down the hallway to get back to the exit. I mean, when they came out the 111 door, they sort of slid into view like they’d been moving fast—which was already odd since they 112 came from the left side of the hall, not the right where the bathrooms are. I even thought about 113 joking, “How are you winded? I’m the one smoking a cigarette” but I let it slide. 114 Anyway, we cut across the softball field toward the South Parking Lot. Dannie suddenly 115 seemed… different. They were nervous, fidgety, just not the same as before. I tried to joke about 116 how long they’d made me wait, but that only made things worse. Dannie got defensive, saying 117 they couldn’t make everyone happy, then sarcastically apologized for wasting my “busy, important 118 life.” Before I could respond, Dannie abruptly jogged ahead, saying they had to hit the books and 119 couldn’t waste time hanging out in parking lots with people like me, as if me making jokes meant 120 school wasn’t important to me.
121 From the second Dannie came back from that so-called bathroom trip, I could tell 122 something was off. I couldn’t put my finger on it, but Dannie was just so strange. Way more on 123 edge than when we were in the lab earlier. 124 Later, when I heard about the fire, my mind went straight back to that moment. It felt like 125 too much of a coincidence, so I called the Leon County Fire Department and told them what I’d 126 seen. I wasn’t 100% sure—it’s not like I saw anything happen—but it just seemed suspicious. I 127 haven’t talked to Dannie since that night.
31 research that can go up in smoke in minutes. That’s especially true when it comes to Tabard 32 University, a place that’s so near and dear to me. I intend to see that justice is done. 33 As part of our investigation, we focused on identifying the fire’s point of origin and 34 determining how quickly it spread. We were unable to conduct a full review of all materials present 35 in the lab at the time of the fire, as the damage to the site was too extensive to allow for a conclusive 36 analysis. Different chemicals, papers, or other substances could have influenced the burn rate— 37 either accelerating or delaying how the fire spread. 38 Our investigation concluded that the fire began in a laboratory (Lab 2A) on the backside 39 of the building, facing away from the main campus and toward an empty softball field and parking 40 lot. The Lubben Natural Sciences Building, constructed in the 19 6 0s during a southward campus 41 expansion, consisted of a concrete shell with wood, plaster, and drywall interior and stood eight 42 stories tall. Due to the sloped terrain, the south side’s ground level corresponded to the second 43 floor of the building, while the north side’s ground level was the first floor. I believe this 44 configuration of the building delayed detection and explains how the fire went unnoticed for 45 approximately 45 minutes. Smoke gradually filled the upper floors. Eventually, the rising pressure 46 caused several windows on the south side to blow out, releasing large plumes of smoke into the 47 air. 48 I’ll note that despite the damage to the building, I have extensive knowledge and familiarity 49 of the building. The Lubben Natural Sciences Building had a major gas leak several years ago and 50 I assisted with the investigation and remediation of the incident. That issue was fully remediated 51 and passed inspection at the time. Another follow-up inspection already scheduled for the weeks 52 after this fire occurred, but obviously this inspection did not occur. While there was no immediate 53 indication that the old gas issue contributed to this fire, we documented it as part of the building’s 54 safety history. 55 When our department arrived on scene, roughly one-third of the building had already been 56 destroyed. This fire was particularly challenging to fight because the exterior of the building—a 57 solid concrete shell—was still standing, while the interior materials were highly combustible and 58 fully involved in flames. From the outside, our crews had limited options and could only attack 59 the fire by spraying water through the windows. By the time we fully extinguished the fire, much 60 of the building had been lost. Only the concrete shell remained, along with two lecture halls and a 61 few offices on the far west end that were spared from complete destruction.
62 Through an analysis of the degree of charring across rooms and floors, we determined that 63 the fire originated in the lower eastern section of the building’s second floor. Our investigation 64 focused on Lab 2A, where we found the remains of a hot plate identified as the likely source of 65 ignition. This model of hot plate was unique to Lab 2A, no other labs in the building had this 66 model. The identified burner had been located on Lab Station #1, positioned in the southeast corner 67 of the room. 68 Although the hot plate’s plastic temperature knob had melted completely, we determined 69 that it had been set to its maximum heat level—approximately 700 degrees Fahrenheit. This 70 conclusion was based on forensic review of the underlying metal cylinder where the knob had been 71 attached, which had rotated fully to the right. In contrast, every other hot plate recovered from the 72 lab was rotated fully to the left, indicating the “off” position. From this, we concluded that the hot 73 plate had been intentionally set to create sustained, maximum heat. Because of severe fire damage 74 to Lab 2A, including the destruction of both the light switch and the lab’s master power switch, 75 we could not determine whether the master switch, which controlled the electrical power to the 76 room, was on or off when the fire began. We also did not review specifics of any safety shut-off 77 features that hot plate model may or may not have had. 78 Working with campus safety and the Leon County Police Department (LCPD), we 79 retrieved door access records from the university’s security system. These records showed that the 80 last three people to leave the building on the evening of the fire were Fenix Blake, Dannie Dawson, 81 and C.J. Schultz. According to the Paul and Frances Lubben Natural Sciences Building Student 82 Activity Log, Schultz exited through the East Lot door at 7:24 p.m., while Blake left from the West 83 Lot door at 7:33 p.m. Dawson exited with Schultz at 7:24 p.m., re-entered immediately afterward 84 through the same door, and finally exited the East Lot door again at 7:35 p.m. Dawson’s presence 85 in the building was corroborated by a social media post made on Dawson’s Tabard Tabs account, 86 a campus-based social media platform often called “TTabz.” The post showed Dawson in Lab 2A 87 on the day of the fire. 88 It’s important to note that while each person is expected to scan their identification card 89 individually, the doors briefly remain unlocked, allowing multiple people to enter or exit without 90 scanning. As a result, these records may not perfectly reflect every individual’s movement in or 91 out of the building. 92 Following standard procedures for incidents occurring on campus after 6:00 p.m., we
