How the State Manufactured Accusers

Only four of the thirteen accusers came forward without detectives first locating them. Jannie Ligons, the first accuser, reported immediately, before the case became public. The forensic evidence did not support her claims and there are numerous holes in her story. Read more about Ligons here. Terri Morris also reported on her own, although the date, location, and patrol-car description she supplied did not point to Daniel. Shardayreon Hill and Kala Lyles came forward only after seeing media coverage of the case. Lyles was already on an investigative contact list, but contacted police before detectives reached her. She claimed Daniel raped her through the fly of his pants for twenty to thirty minutes just hours before the pants were collected, but her DNA was not on his fly. At the end of Hill's recorded police interview, after the detective seemed to be finished, she stood up and said: “Even if he didn’t like even rape nobody or nothing he’s still getting in contact with people he arrested.” Watch it. The remaining nine women were located and approached through searches of Daniel's police contacts. Scott Adams 01534, 01536, 01537, 05879; Holtzclaw v. State, 2019 OK CR 17, ¶ 3; Trial Tr. 3627; Scott Adams 05878, 05880; Trial Tr. 1422:20–1424:3, 1731:1–4.

None of the four who came forward on their own had physical evidence supporting her account. The only DNA linked to any accuser belonged to Adaira Gardner, whom detectives located in October 2014, four months after the pants were collected. Read more about the DNA here. Forensic Examination Report SD-14-273 (Nov. 12, 2014).

Ligons's report is what opened the investigation, yet the profile investigators built afterward — Black women with drug or prostitution histories and, in the State's trial narrative, legal exposure such as outstanding warrants — does not match Ligons herself.

Detective Davis's own report recorded Ligons's only prior arrest, in 1985, as resulting in no charges. There is no prostitution history in that record. More to the point, Daniel never ran Ligons's name during the stop, so whatever a records check might have shown could not have been the reason he chose to stop her. Scott Adams 00061, 00022, 00098.

Race doesn't solve the problem either. Ligons's red Pontiac had darkly tinted windows. At trial, Detective Kim Davis was shown State's Exhibit 8, a photograph of the car taken around noon. Asked, "Broad daylight. Can you see inside of that car?" she answered, "No." Asked whether it would be even harder to see inside at 2:00 a.m., she answered, "Yes." Nothing in the record shows Daniel knew the driver was a Black woman when he decided to pull the car over. Trial Tr. 1099; State's Ex. 8.

Muzny offered an explanation for the gap in a 2019 civil deposition. Asked why the profile's criteria didn't reflect Ligons's own background, he said the drug-and-prostitution history the profile was built around came from Terri Morris, not Ligons: "That was the — that would be the, I guess, the history that you had with Terri Morris." Muzny Dep. 207:2–9, 208:9–12 (Mar. 26, 2019).

That doesn't resolve the circularity. The profile the department built out of Morris's background is the same profile McConnell later told the jury explained Daniel's selection criteria across all thirteen women — including, by implication, Ligons, the woman whose report started the case and whom that profile doesn't fit.

The answer raises a second problem. The history the profile was built from belonged to a complainant who described a location, date, and patrol car that didn't match Daniel. The Sex Crimes supervisor had declined to send a detective to Morris on credibility grounds, and three days later Major Wenzel described her internally as "a crackhead who was trading sex for a rock." The department built its search for victims around the background of a woman it had written off as a crackhead not worth a detective's time. Scott Adams 01125; Wenzel dep. 38, 54, 138–39; OKC 36361 / Wenzel dep. Ex. 8.

Yet after Ligons, investigators deliberately searched for Black women with drug or prostitution histories, and the State later pointed to exactly those characteristics as evidence Daniel had chosen a certain kind of victim. Scott Adams 01001; Trial Tr. 2385–88, 4151, 4187–88. The supposed pattern did not generate the search. The search generated the pattern.

Defense counsel made this same argument to the jury. In closing, Scott Adams asked directly where the profile had come from, using Ligons as his example: "Ms. Ligons had neither one of those [a drug history or a prostitution history]... Where did that come from?" He argued that after Daniel was placed on leave, investigators ran a "retroactive" rather than a "proactive" investigation, and told the jury "that's the flaw" — that the profile "they have all the sudden developed" was built "out of thin air" after the fact, then applied backward to the women police went looking for. Trial Tr. 4205–06. The jury convicted anyway.

Detectives repeatedly opened contact with women by saying police had received a "tip" that they might have been sexually assaulted by an Oklahoma City police officer. In many of those contacts, no such tip existed. At a September 2014 bond hearing, Detective Kim Davis admitted it outright: "yes, I lied, I had not received a tip." She said she used the line because she didn't want to tell a woman that police were investigating an officer several other women had already accused, or reveal how large the search had become. Mot. Hr'g Tr. 112:16–113:15 (Sept. 3, 2014).

At trial, the prosecutor asked Davis whether "I received a tip" was an approach she used with women among the "30-some-odd ladies" who ultimately said nothing had happened. She answered yes. Asked why she'd used that word with Florene Mathis specifically, Davis gave a different account of the word than the one she'd given at the bond hearing a year earlier. In September 2014, she'd called it a lie. At trial, she described it as accurate: when Lieutenant Muzny handed her a packet on a woman to contact, "that kind of is a tip. That's how we get things on... a lot of our assignments... and I'm acting on that tip." In her 2019 deposition Davis put the number at thirty-four: I think there was 34 that said we're investigating this. And they would say, no, nothing happened. Trial Tr. 2423:15–2424:19; Davis Dep. 249:25–250:6 (Jan. 29, 2019).

The surviving reports show the sequence. Davis wrote that when Sherry Ellis returned her call, she told Ellis she'd received a "tip" that Ellis might have been sexually assaulted by a police officer; Ellis said she had. Gregory wrote that he told Tabitha Barnes he had a "tip" that she might have been the victim of an unreported sexual assault; Barnes responded that an officer had touched her inappropriately. Davis used the same premise at Carla Johnson's door: told police had received a tip that she might have been sexually assaulted by an officer, Johnson answered, "Yes mam, that did happen." Florene Mathis's jail interview opened the same way. Mathis testified she had never told anyone before detectives approached her. Davis Supplemental Report on Sherry Ellis, Aug. 13, 2014; Gregory Supplemental Report on Tabitha Barnes, Aug. 24, 2014; Davis Supplemental Report on Carla Johnson, Aug. 14, 2014; Standard Supplement Report on Florene Mathis, Aug. 13, 2014 (Scott Adams 01427–29).

Carla Raines gives the clearest recorded example of that framing preceding a changed account. On cross-examination, she agreed she'd said no roughly five times before Gregory told her he was investigating "a really bad guy" who "has lots of victims." Only after that did she begin describing the encounter at 16th and Fonshill. Gregory acknowledged his written report left out the repeated denials, his reference to the investigative list, the "really bad guy" description, and the mention of "a lot of victims." He defended the report as a "synopsis," and on redirect said he'd "put together a report to make it flow for the reader," knowing the full recording would go to the defense. The full, unedited audio of the interview is online: Listen to Gregory's interview of Carla Raines ↗. Trial Tr. 2200, 2204–05, 2221–22, 2245–47.

The recording shows her account changed twice before it reached Daniel. Raines first denied that any officer had been inappropriate with her. When Gregory kept pressing, the only officer she could think of was someone else entirely: "There's only one officer that I know a few years back [...] he's a black cop that used to come around here." Later in the interview she described him again: "I was on the South side [...] at the gas station, and he exposed his self to me. That was a black officer. I guess they was doing some sort of sting, or whatever, and he exposed his self to me." Only after that did she say she had been pressured to expose her breasts to an officer, the encounter police later attributed to Daniel. Raines Audio Interview with Det. Gregory, Aug. 15, 2014.

Rosetta Grate's first interview was compromised before Davis ever walked into the room. On August 15, Davis and Detective Valari Homan went to the home of Grate's father, Johnnie Grate, told him they were investigating a sexual assault, and left a card asking Grate to call. Eleven days later, Grate was booked into the Oklahoma County Jail on unrelated charges; Davis and Homan went to interview her there on August 27. By then the case was public. Daniel had been arrested on August 21, and within a day his name, his photograph, and the charges — with an affidavit describing at least seven victims — were in local and national news. Before Davis said anything about why she was there, Grate spoke first: "How do you know, did he confess?" On cross-examination, Davis agreed her father had already told Grate about the visit — "Are you the two that went to my daddy's house?" Asked whether she'd checked the jail's recorded phone log to see what father and daughter had actually discussed in the interim, Davis said she didn't know if that conversation had even happened while Grate was in custody, then two questions later agreed that it had. The jail records every inmate call; nothing in the trial record shows anyone reviewed it. Trial Tr. 2733, 2772; CBS News/AP, Aug. 22, 2014, News 9, "OCPD Officer Arrested", News 9, "Affidavit: At Least 7 Victims", MLive, Aug. 2014.

A 2020 defense-retained report by forensic criminologist Brent E. Turvey and forensic psychologist Aurelio Coronado Mares sharply condemned the method. Investigators, they wrote, "routinely started interviews by giving the false impression" that police already had evidence the woman was a victim, creating what they called "a coercive negotiation." They warned the tactic could contaminate statements and produce false allegations, particularly when investigators suggested the suspect's identity, invoked other alleged victims, or used a woman's own legal exposure against her. They also called the failure to record the women who denied anything happened "a violation of competent investigative practice," and the no-recording directive itself "such a biased order." B. Turvey & A. Coronado Mares, Forensic Report: Crime Scene Analysis & Case Linkage (July 1, 2020), at 8–9.

How each accuser reached the case, what she was told before she said anything, whether her first interview was recorded, how she identified Daniel, and what the jury did with it.

Sources: the pages of this site and the records they cite; charges and verdicts from the verdict and sentencing transcripts (Trial Tr. 4324–26; Motion for New Trial & Sentencing Tr. 24, 46); on the “tip” and “inappropriate with women” openings, Davis Dep. 249:17–250:6 (Jan. 29, 2019).