IN THE DISTRICT COURT OF MITCHELL COUNTY, KANSAS - CASE NO. MC-2oa5-CR
STATE OF KANSAS, PLAINTIFF
vs. CHRISTOPHER JAMES HERZ, DEFENDANT
COMPLAINT/INFORMATION
Mark J. Noah, a duly appointed, qualified and acting County Attorney of Mitchell
County, Kansas, and for and on behalf of the state of Kansas being first duly sworn on
oath gives the Court to understand and be informed, that he is informed and verily
believes:
COUNT ONE
That on or about January' 13, 2025, the above-named Defendant, within Mitchell
County in the State of Kansas, then and there being, did then and there contrary to the
statutes of the State of Kansas unlawfully and feloniously and while in the commission
of operating a motor vehicle in Violation of K.S.A. 8-1567, kill a human being (Travis
Gene Cady).
Crime: Involuntary Manslaughter
Statute: K.S.A. 215405(a)(3), (b)(2), and amendments thereto
Penalty: Level 4 Person Felony (1'72 months/$300,000)
COUNT TWO
That on or about January 13, 2025, the above-named Defendant, within Mitchell
County in the State of Kansas, then and there being, did then and there contrary to the
statutes of the State of Kansas unlawfully and feloniously and while in the commission
of operating a motor vehicle in violation of K.S.A. 8-1567, did cause bodily harm to
another ((Travis Gene Cady), in a manner whereby great bodily harm, disfigurement or
death can result.
Crime: Aggravated Battery
Statute: K.S.A. 215413(b)(3)(B), (h)(2)(D) and amendments thereto
Penalty: Level 8 Person Felony (23 months/$100,000)
COUNT THREE
That on or about January 13, 2025, the above named Defendant, within Mitchell
County in the State of Kansas, then and there being, did then and there contrary to the
statutes of the State of Kansas unlawfully and intentionally operate or attempt to
operate a vehicle while under the influence of any drug or combination of drugs to a
degree that rendered him/her incapable of safely driving a vehicle.
Crime: Driving while Under the Influence of Alcohol - 1st
Statute: K.S.A. 8-1567(a)(4), (b)(1)(A) and amendments thereto
Penalty: Class B Nonperson Misdemeanor (6 months/$ 1,000)