United States District Court

WESTERN DISTRICT OF MISSOURI

WESTERN DIVISION

UNITED STATES OF AMERICA

Unlawful Photographing of Defense Installation
v. Without Authorization
18 U.S.C. § 795
QILINWU NMT 1 Year Imprisonment
[DOB: 03/0111989], NMT $100,000 Fine
NMT 1 Year Supervised Release
Class A Misdemeanor
$25 Mandatory Special Assessment

CRIMINAL COMPLAINT
Case Number: 26-MJ-OOOOI-JAM

I, the undersigned complainant, being duly sworn, state the following is true and correct to
the best of my knowledge and belief:

Between on or about December 2,2025 and December 3,2025, in the Western District of

Missouri, the defendant, QILIN WU, knowingly and intentionally photographed and took video

footage of a vital military installation and equipment which were classified, designated, and

marked under the authority and at the direction of the President as restricted, and which were

located within a military reservation, base, airfield, station and district, pursuant to Executive

Order No.1 0 104, without first obtaining permission of the commanding officer, to include: a video

of a Northrop B-2 Spirit aircraft taking off from Whiteman Air Force Base ("WAFB"); a

photograph of the eastern perimeter fence line ofW AFB near the Weapons Storage Area ("WSA");

a video of the southeast side of WAFB; several photographs depicting Arnold Gate and a B-52

static display on the north side of WAFB, to include an image of the security fence that obscures

the B-2 hangars inside the base perimeter; a photograph of the security fence on the South end of

Case 4:26-mj-00001-JAM Document 1 Filed 01/06/26 Page 1 of 2

the runway that also depicts the instrument landing system; a photograph that appears to depict

B- 2 navigation and anti-collision lights; and a photograph of the LeMay commercial vehicle gate,

an access point at WAFB, capturing the fence line of the base housing along the roadway, all in

violation of Title 18, United States Code, Section 7~ (~ L

Michael A. Smith
Special Agent
Federal Bureau of Investigation

Telephonically at 3:54 p.m., with signatures con rmed

Sworn to before me and subscribed in my presence,

January 6, 2026 at Kansas City, Missouri

Date City and State

HONORABLE JILL A. MORRIS

United States Magistrate Judge
Name and Title of Judicial Officer Signature of Judicial Officer

2
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fi
 Case No. 26-MJ-0000I-JAM

AFFIDAVIT

I, Michael Alexander Smith, being duly sworn, state under oath that:

1. I am a Special Agent with the Federal Bureau of Investigation ("FBI") and have
been since October 2023. I am currently assigned to the Kansas City Division,
Kansas City, Missouri, on the Counterintelligence squad. In the course of my
duties, I have worked closely with Air Force Office of Special Investigations
("OSI") on national security matters pertaining to Whiteman Air Force Base
("WAFB"). I am familiar with trade craft and techniques employed by foreign
adversarial nations, as well as the methods those nations use to collect intelligence
on elements of U.S. military infrastructure. I received my initial Special Agent
training at the Counterintelligence Special Agents Course at Fort Huachuca,
Arizona in 2018. I served as a Counterintelligence Special Agent with the
United States Army from 2018 - 2023. I graduated as a FBI Special Agent from
the FBI Academy, Quantico, Virginia in March 2024. In connection with my
official duties, I have conducted both criminal and national security investigations.
Based upon my training, experience, and investigation in this matter, I believe the
following facts to be true and correct:

2. This Affidavit contains information necessary to support probable cause for this
complaint. It is not intended to include every fact or matter observed by me or
known by law enforcement. The information provided is from my participation in
this investigation as well as from reviewing investigative reports, physical evidence
obtained during the investigation, my review of records and documents, from
discussions with others, including law enforcement officers, and from my personal
knowledge, training, and experience.

3. Title 18, United States Code, Section 795, is part of the Espionage Act. More
specifically, 18 U.S.C. § 795 (i) authorizes the President of the United States to
defme certain vital military and naval installations or equipment as requiring
protection against the general dissemination of information relative thereto; and (ii)
prohibits, in the interest of national defense, the making of any photograph, sketch,
picture, drawing, map or graphical representation of such vital military or naval
installations or equipment without first obtaining requisite permissions (e.g., from
the commanding officer of the military or naval post).

4. In Executive Order 10104, then-President Harry Truman, in the interests of the

national defense, identified vital military and naval installations and equipment
requiring the protection afforded by 18 U.S.C. § 795. See Executive Order 10104.
The Executive Order specifies that "[a]ny military, naval, or air-force reservation,
post, arsenal, proving ground, range, mine field, camp, base, airfield, fort, yard,
station, district, or area" classified as "top secret, secret, confidential, or restricted"
falls under the protection afforded by 18 U.S.C. § 795. See Executive Order 10104.

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 Case No. 26-MJ-00001-JAM

5. On December 2, 2025, at approximately 1645 hours local (CST), Special Agent

Donald Pearce, an Air Force Office of Special Investigations ("AFOSI") Special
Agent ("SA") assigned to Detachment 811, WAFB, Missouri, received notification
of a suspicious vehicle parked outside the southeast perimeter fence of WAFB.
WAFB is located within the Western District of Missouri. The suspicious vehicle
was described as a Toyota Sienna van bearing Massachusetts license plate number
3RGG16. Security Forces Patrolman Jacob McCleerey, went to the location and
made contact with the sole occupant of the van, later identified as Qilin WU (male,
DOB: 03/0111989; address: 42 Higgins Street, Unit 1, Allston, Massachusetts).l
WU presented a Massachusetts driver's license bearing license number
SA310 1857. During the encounter, WU spoke limited English and relied on a
translation application on his phone, which the patrolman observed contained what
appeared to the patrolman to be Mandarin characters. WU stated that he had
driven from Boston, Massachusetts, specifically to observe the B-2 Spirit aircraft.
WU inquired when the B-2 would be flying. The patrolman advised WU that WU
was permitted to remain at his current location to watch aircraft activity, but WU
was not authorized to take photographs or video recordings of the installation.
WU acknowledged this instruction by responding: "Okay." When asked directly
ifhe had taken any photographs, WU replied that he had not, explaining that WU
had not yet seen the B-2 aircraft. Following the encounter, the patrolman notified
Johnson County Dispatch to document the suspicious vehicle. By the time a
deputy arrived on scene, WU had departed the area.

6. The next day, on December 3,2025, at approximately 12:00 p.m., AFOSI SA Kerry
McGuire responded to a report of a suspicious vehicle positioned outside the
southeast perimeter fence of WAFB. Upon arrival, SA McGuire made contact
with the driver of the vehicle, who identified himself as Qilin WU. WU presented
a valid Massachusetts driver's license for identification. The suspicious vehicle
was the same Toyota Sienna van bearing Massachusetts license plate number
3RGG16 that the Security Forces Patrolman had observed on December 2,2025.
During this new encounter on December 3, 2025, SA McGuire noted that WU's
English proficiency appeared to be limited. WU again relied primarily on a
translation application installed on his cellular phone, which appeared to display
Mandarin characters, to facilitate communication with the agent. WU provided
additional background information regarding his entry into the United States and
his personal history. WU stated that he entered the United States in or around
2022 by crossing the Mexican border into Arizona on foot. He explained that prior
to this crossing, he had flown from China to Ecuador and then traveled north
through Mexico. WU disclosed that he was detained at some point by U.S.
Customs and Border Protection, but WU reported that he was subsequently released
after he claimed asylum. WU further stated that he had previously served in the

1 During the consensual contact with the Security Forces Patrolman Jacob McCleerey, WU

provided a copy of his Massachusetts driver's license that referenced this personally identifiable
information.
2

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 Case No. 26-MJ-0000I-JAM

Chinese military. While serving in the Chinese military, WU stated that he

witnessed troubling events that led him to conclude conditions in China were "no
longer good." He elaborated that he had worked as a firefighter and he also served
two years in the Central Military Band of the People's Liberation Army of China,
specifically as a saxophone player in the Soldiers of Jun Band. When asked to
present immigration documentation, WU initially refused to do so unless the SAs
were equipped with body-worn cameras, explaining that such a process felt "more
formal." Shortly thereafter, a Johnson County, Missouri Sheriffs Deputy arrived
on scene, at which point WU presented his Chinese passport bearing passport
number EA9787632. WU consented to the SAs photographing both his
Massachusetts driver's license and his Chinese passport for evidentiary purposes.

7. On December 3, 2025, during the course of the consensual, non-custodial interview,

the Johnson County Sheriffs Deputy who arrived on scene had a body camera that
recorded the interaction once he was present. A copy of that video footage has
been secured by OS!. WU disclosed that he had taken photographs and videos of
the installation. WU specifically admitted that he recorded video footage of a B-
2 Spirit aircraft taking offlate on December 2,2025. When asked by SA McGuire
if the images and videos could be reviewed, WU agreed and consented to SA
McGuire using a cellular phone camera to capture screenshots directly from WU's
cellular phone. SA McGuire took a total of eighteen photographs ofWU's camera
that was displaying photographs that WU admitted he had taken using his camera
on WU's cellular phone. SA McGuire preserved the photographs as evidence.
The photographs WU showed SA McGuire contained imagery of sensitive areas of
WAFB, including the perimeter security fence line adjacent to the Weapons Storage
Area ("WSA") fence line, static aircraft displays located at the Arnold Entry
Control Point, and a security barrier at the Arnold Entry Control Point that obscures
the B-2 hangars on the flightline. Additionally, WU showed SAs a nighttime
video that depicted a B-2 aircraft taking off from WAFB, with audible afterburner
activity. WU stated on December 2,2025, he traveled from Boston to New York
and then to Missouri with the specific intent of observing a B-2 Spirit aircraft at
WAFB. WU described himself as an aviation enthusiast. WU claimed that the
B-2 was his favorite aircraft, followed closely by the F-35. He further disclosed
that he had previously visited Langley Air Force Base in Virginia, where he
admitted that he photographed multiple military aircraft, including an A-I0, a B-2,
and a B-52.

8. On December 5, 2025, AFOSI SA Pearce and SA McGuire reviewed the images

and videos taken by SA McGuire during the consensual encounter with WU.
These images and videos were documented as evidence. The review confirmed
eighteen screenshots had been captured with WU's consent. Below is a
description of each recorded image:

• Image_175551688 - Date Stamp: 30 Nov 25 at 8:10PM; Description: screenshot

of highway systems near Houston Texas, specifically Space Center Houston and
League City.

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 Case No. 26-MJ-0000I-JAM

• Image_175552609 - Date Stamp: 30 Nov 25 at 8:12PM; Description: Screenshot

of highway systems near San Antonio and Houston. Specifically, a marker for
Reynosa, Mexico. Screenshot also has a WeChat message captured: translation
from Mandarin to English, First Line: Wang Zhou's Mom (or Wang Zhuo's
Mother) Second Line: [voice message] 11 seconds (Agent Note: Reynosa is a
border city in Mexico where thousands of foreign nationals attempt to enter the
u.S. each year).

• Image_175627393 - Date Stamp: unknown (SA Note: WU stated this photograph

was taken on 2 December 2025); Description: east side ofW AFB, depicts perimeter
of base near the Weapons Storage Area (WAS).

• Video_175655000 - Date Stamp: 2 Dec 25 at 2:23PM; Description: Video

appearing to be from a vehicle making a left hand turn on highway Y heading south.
Video depicts perimeter fence line near the WSA.

• Image_175711738 - Date Stamp: unknown (SA Note: WU stated photograph was

taken on 2 December 2025); Description: image depicts roadway leading up to
Arnold Gate on the north side of WAFB. Static B-52 is seen in the background.

• Image_175715595 - Date Stamp: unknown, (SA Note: WU stated photograph was

taken on 2 December 2025); Description: image depicts sidewalk leading up to the
B-52 static display at Arnold Gate. WAFB water tower is seen in the background.

• Image_175717352 - Date Stamp: unknown, (SA Note: WU stated photograph was

taken on December 2, 2025); Description: image depicts the Arnold Gate sign for
WAFB which is near a gate that allows restricted access onto the installation.

• Image_175719757 - Date Stamp; unknown, (SA Note: WU stated this photograph

was taken on December 2, 2025); Description: image depicts security fence as well
as the security barrier that obscures the view of the B-2 hangars in the background.

• Image_175722892 - Date Stamp; unknown, (SA Note: WU stated photograph was

taken on 2 December 2025); Description: image depicts the security perimeter
fence on the south end of the runway. The instrument landing system ("ILS") is
seen in the background.

• Image_175728132 - Date Stamp; unknown, (SA Note: WU stated photograph was

taken on 2 December 2025); Description: image appears to be from a vehicle
traveling westbound on SE 23 Highway near LeMay Commercial Vehicle Gate.
WAFB housing is seen on the right side along with perimeter security fence line
and base lighting.

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• Image_175734105 - Date Stamp; unknown, (SA Note: WU stated photograph was

taken on 2 December 2025); Description: blurry image of sunset. It appears to be
south of base near LeMay Commercial Vehicle Gate.

• Image_175738171 - Date Stamp; unknown, (SA Note: WU stated photograph was

taken on December 2, 2025); Description: image is dark and blurry; however, B-2
navigation and anti-collision lights are seen in the photograph.

• Image_175745999 - Date Stamp; presumed 2 Dec 25 at 9:16PM (SA Note: WU

stated photograph was taken on 2 December 2025); Description: a screen shot of
W AFB from a GPS satellite view. A blue dot appears to indicate WU's location
at the time the screen shot was captured. (Affiant's Note: This information
coincides with WU's location when the Security Forces patrolman and Special
Agents interacted with him on December 2 and 3, 2025.)

• Image_175751278 - Date Stamp; 2 Dec 25 at 10:07PM (SA Note: WU stated

photograph was taken on 2 December 2025); Description: Screenshot containing
Mandarin text dated "Yesterday" at 10:07 pm. Below is a copy of that screenshot:

SA McGuire used Google Translate for a machine translation of this image and
captured the following screenshot depicting the English translation:

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 Case No. 26-MJ-0000I-JAM

• Image_175801149 - Date Stamp; unknown (SA Note: WU stated this photograph

was taken on December 2, 2025); Description: SA McGuire attempted to capture a
video but inadvertently captured a photograph of the video. The video was
successfully captured as Video_175804000.

• Video_175804000 - Date Stamp; unknown (SA Note: WU stated this video was
taken on December 2, 2025); Description: the video is dark and blurry; however,
B-2 navigation and anti-collision lights are seen in the video and the afterburner of
the dual engine aircraft is heard while a B-2 is taking flight over WAFB.

• Video_175824000 - Date Stamp; unknown (SA Note: WU stated video was taken
on 2 December 2025); Description: this video is dark and blurry; however, B-2
navigation and anti-collision lights are seen in the video in the upper righthand
corner and the afterburner of the dual engine aircraft is heard while a B-2 is taking
flight over WAFB.

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 Case No. 26-MJ-00001-JAM

• Video_175919000 - Date Stamp; unknown (SA Note: WU stated video was taken
on December 2, 2025); Description: video depicts a hand pressing a button on the
upper console of a van. The video then depicts the south end of the runway
perimeter security fence line and then pans to the east showing the roadway.

9. The United States' critical infrastructure provides the essential services that
underpin American society. It is comprised of physical and virtual assets and
systems so vital to the United States that their incapacity or destruction would have
a debilitating impact on national security, national economic security, or national
public health or safety. The Department of Defense ("DoD") has further
established critical infrastructure that is identified as networked assets and facilities
essential to the projection, support and sustainment of military forces and
operations worldwide. Defense Critical Infrastructure ("DC I") consists of
infrastructure owned and controlled by the DoD that is critical to the execution of
one or more operational plans; and infrastructure on which the DoD depends on for
operations but does not own or control, e.g., power, water, communications.

10. WAFB hosts critical DoD infrastructure that is essential to the Department of the
Air Force's nuclear deterrence capabilities and a variety of other DoD missions.
WAFB plays a central role in national security by housing the B-2 Spirit stealth
bomber fleet, enabling precision global strike, strategic deterrence, and nuclear
readiness. Its assets provide advanced stealth, radar-evading technology, and
secure command and control systems that ensure the credibility of the
United States' nuclear triad. Consequently, the incapacitation or destruction of
WAFB would have a debilitating impact on the nation's nuclear deterrence posture
and one or more critical DoD missions.

11. Based on DoD Manual 5200.08, Volume 3, which governs physical security and
access control for all DoD installations, I know that this manual specifically applies
to Air Force Bases with strategic assets. Additionally, Facilities Criteria (FC 4-
420-07F, 2018) confirms that bases supporting nuclear missions, such as Whiteman
Air Force Base ("W AFB") with the B-2 Spirit Stealth Bomber, must be treated as
restricted areas with enhanced security. Therefore, WAFB qualifies as a vital
military installation as set forth in 18 U.S.c. § 795 and defined in Executive Order
10104. The aforementioned images and videos that depict WAFB are depicting
vital military installations and equipment.

12. On December 3, 2025, WU provided AFOSI SAs consent to search WU's vehicle.
SAs conducted a plain view search of WU's vehicle with WU's consent. SA
McGuire conducted a preliminary search of the vehicle and discovered bedding
material, food, drinks, and an iPad. SA McGuire did not discover any contraband.
WU permitted agents to look at the iPad; however, when SAs looked at the device
they did not discover any photographs or messages. WU maintained control over
the device, limiting the scope of the consensual search of the device. During the
encounter, WU explained that once he had seen a B-2 Spirit aircraft, he intended to
travel to Florida to observe an F-35 aircraft and then continue on to "Houston Star

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 Case No. 26-MJ-0000I-JAM

Base." SA McGuire asked WU if he would accompany the agents to the Visitor

Control Center to complete paperwork. WU agreed. While enroute to the visitor
center, WU asked whether it would be possible to see or touch a B-2 aircraft. At
the visitor center, the SA requested that WU enroll his biometrics in the Javelin
system. The Javelin is a mobile biometric collection platform capable of
collecting multi-modal biometrics. WU declined, stating that the process was "not
worth the hassle." WU then became visibly discontent with the line of
questioning. WU expressed that he no longer liked Americans, and WU indicated
that he intended to return to China.

13. On December 3, 2025, AFOSI contacted Immigration and Customs Enforcement

("ICE") Enforcement and Removal Operations ("ERO") in Kansas City, Missouri
regarding the immigration status of wu. Deportation Officer Kirk Ellis (DO
Ellis) reviewed immigration indices on WU. WU was identified as an alien from
China. According to ICE, WU entered the United States on or about June 22,
2023, near Nogales, Arizona. At that time, U.S. Border Patrol determined that
WU had entered the United States from Mexico without inspection. WU was
determined to be an illegal alien from China and accordingly was arrested under
the Immigration and Nationality Act. Due to a lack of detention space, WU was
released on his own recognizance while he awaited removal proceedings. On
December 3,2025, WU's next immigration court date was scheduled for February
9,2027. On December 3, 2025, after WU was taken to the WAFB Visitor Control
Center, AFOSI officials placed WU under custody to further investigate the offense
of 18U.S. Code § 795, that is for photographing and sketching defense installations.
WU is still under investigation for this offense. As a result of this encounter, ICE
ERO Kansas City arrested WU for a custody re-determination hearing. WU will
have a hearing before an immigration judge to decide if he should remain in ICE
ERO custody or be released for the remainder of his immigration proceedings. At
the time of the execution of this Affidavit, it is my understanding that ERO has
transferred WU's immigration proceedings from Massachusetts to Kansas City.

14. On December 5, 2025, OSI SA Jessica Gross verified the official flight schedule
for WAFR The schedule confirmed that two B-2 Spirit aircraft departed WAFB
on December 2,2025, at approximately 1730 and 1731 local hours. The B-2 Spirit
is a strategic bomber equipped with classified and sensitive systems throughout its
design and operation.

15. On December 4,2025, FBI SA James Churchill and I interviewed WU. Prior to
serving as a federal agent, SA Churchill was a Mandarin linguist for the FBI. WU
was advised of his Miranda rights verbally and in writing in English and Mandarin.
The interview was both video and audio recorded. WU indicated he understood
his rights and was willing to answer questions. WU stated that, in or around 2023,
he traveled from China to Ecuador. From Ecuador, WU traveled by bus through
Mexico to the United States. WU then walked across the border in the area of
Nogales, Arizona. WU admitted to taking photographs of WAFB using his
cellular telephone. Specifically, WU stated he took photographs of planes in the

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 Case No. 26-MJ-00001-JAM

sky, some of the railing and fencing of the base perimeter, and the B-52 outside of
base. WU stated he was unaware he was not allowed to take photographs. WU
stated he did not see anything that clearly stated he could not take photographs.
WU took a total often photographs and videos. Four of them were taken at night
and the others were taken durmg daytime hours. (Affiant Note: On December 2,
2025, Security Forces Patrolman McCleerey informed WU that he was prohibited
from taking photographs or videos of WAFB. Based on the time stamps observed
on some of the photographs, I know that WU took at least some photographs of
WAFB after WU was told he was not permitted to do so.

16. OS1 SA Jessica Gross coriducted a criminal background check on WU and

discovered that WU has had other interactions with law enforcement officials. On
May 7, 2024, officers of the Key West Police Department encountered an
individual identified as WU at 55 Quay Road, Key West, Florida. WU was
observed camping in his van and his van was documented as a suspicious vehicle
by responding officers. On May 14, 2024, at approximately 0319 local hours, WU
was encountered by Key West Police Department officers at 3681 South Roosevelt
Boulevard, Key West, Florida. During this encounter, officers conducted a field
interview and issued WU a written warning for lodging and camping in his vehicle.
The location of this incident is situated directly within the pathway used by Naval
aircraft for takeoff and landing operations, thereby raising heightened safety and
security concerns.

17. The aforementioned events involving WU photographing at WAFB all occurred

within the City of Knob Noster, County of Johnson, State of Missouri, which is
within the Western District of Missouri. These events give rise to probable cause
that this subject is in violation of various federal laws, including, but not limited to,
Title 18, United States Code, Section 795 (Photographing a Defense Installation).

FURTHER, YOUR AFFIANT SAYETJlm-UGHT. //

/ /1'1 (./ U- e;:::::-
Michael Alexander Smith
Special Agent
Federal Bureau of Investigations

Telephonically/remotely or otherwise subscribed to and sworn to before me this 6th day of

January 2026.

HONORABLE JILL A. MORRIS

United States Magistrate Judge
Western District of Missouri

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