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Midwest Transparency Audit

Because government operates best in the light.

Ray County Sheriff Sunshine Request Data

This page contains the compiled public records, statutory correspondence, and inter-agency agreements obtained regarding the Ray County Sheriff’s Office and its operational integration into regional Automated License Plate Reader (ALPR), Flock, tracking networks.

Executive Overview:
The Ray County Sheriff’s Office does not directly own or maintain physical Flock Safety ALPR camera hardware. Instead, the agency utilizes a zero-cost infrastructure backdoor, intercepting massive sums of vehicle tracking data generated by municipal hardware networks—specifically those owned and paid for by the City of Richmond.
Our audit exposed a critical transparency failure: when formally requested to produce data-sharing agreements under the Missouri Sunshine Law, the Sheriff's Office claimed no responsive records immediately existed and stalled the investigation. However, an unredacted copy of an active, multi-agency Data Sharing Memorandum of Understanding (MOU) was successfully recovered through a parallel audit of the Richmond Police Department, proving that the Sheriff's Office concealed an active tracking partnership signed just two months prior.

The Data-Sharing Matrix (The Hidden MOU)

The Sunshine Law Battle: Audit Timeline

The public record log details a calculated effort by county command staff to obscure their active utilization of regional surveillance networks:

  • July 8, 2026: Midwest Transparency Audit LLC submitted a formal Sunshine Law request to the Ray County Sheriff's Office demanding all Flock Safety contracts, data-sharing integrations, and internal usage policies governing how deputies utilize ALPR data.

  • July 10, 2026: Lt. Colonel Tom Noon responded on behalf of the agency, issuing a flat disclaimer stating that the Sheriff's Office “does not have any current or past contracts, subscription agreements, or service agreements with Flock Safety,” and redirecting the inquiry entirely to the City of Richmond. Colonel Noon stated that the agency was merely “reviewing the remaining portions” of the request to see if any other records existed.

  • July 14, 2026: We issued a Formal Notice of Incomplete Production and Statutory Objection. We called out the open-ended review period as an explicit violation of § 610.023.3, RSMo, which requires a definitive production deadline.

  • The Catch: While Ray County command staff continued to ignore statutory timelines, our parallel audit into the City of Richmond yielded the smoking gun—the active data-sharing MOU signed directly by Sheriff Blackwell on May 13, 2026.

Despite administrative claims to the contrary, the Ray County Sheriff's Office is legally bound to a centralized surveillance network via an active, three-party contract:

  • The Agreement: Documented via DocuSign Envelope ID: 52A0BCAD-28A7-8F4F-81AA-C8EB6C1CB230, the Sheriff's Office entered into a formal Data Sharing Memorandum of Understanding alongside Flock Group Inc. and the Richmond Police Department.

  • Execution Date: The contract was fully executed on May 13, 2026, with direct signatures from Ray County Sheriff Gary Blackwell, Richmond Police Chief Scott Bagley, and Dan Haley, Chief Legal Officer for Flock.

  • The Terms: Under Section 1 and 2 of the MOU, Ray County deputies and investigators are granted full, non-exclusive access to query, view, search, and capture photos and videos recorded by Richmond's seven-camera Flock footprint. County personnel are provisioned with unique FlockOS user credentials linked directly to their official agency email addresses.

  • The Fine Print: Section 6 mandates that no financial commitment is required from Ray County to intercept this municipal data stream. Crucially, Section 13 establishes that any legal controversy or claim arising from this local Missouri tracking network is governed exclusively by the laws of the State of Georgia, with Flock's structural liability for direct damages strictly capped at a mere $100.

Status: Complaint Filed to Attorney General. On July 14, 2026: We issued a Formal Notice of Incomplete Production and Statutory Objection. We called out the open-ended review period as an explicit violation of § 610.023.3, RSMo, which requires a public body to provide a detailed cause for delay alongside a specific date and time for production. We demanded that the agency produce the remaining records, a formal statutory denial, or a legally compliant timeline within 24 hours. Following the July 14 enforcement notice, the Ray County Sheriff's Office completely severed communication. In response to the agency's deliberate non-compliance and total refusal to communicate, Midwest Transparency Audit LLC filed a formal Sunshine Law Complaint with the Missouri Attorney General's Transparency Division. The complaint documents Ray County's persistent statutory violations—specifically their failure to commit to a firm production date and the bad-faith withholding of the inter-agency data-sharing MOU executed with Richmond on May 13, 2026, which was recovered independently via our parallel municipal audits.

CALL TO ACTION: Demand Commission Oversight in Ray County 
When law enforcement agencies operate in the shadows, public trust fractures. The recent discovery that Lt. Col. Noon and the Ray County Sheriff’s Department actively concealed their Memorandum of Understanding (MOU) with the Richmond Police Department is a direct affront to open governance, and it demands immediate intervention from the Ray County Commission.

As the body responsible for funding and overseeing the Sheriff’s Department, the Commissioners cannot allow command staff to bypass accountability. When these agreements are deliberately buried, the Commission is kept in the dark, and independent public oversight is paralyzed. We strongly encourage all citizens to contact the Ray County Commissioners and demand that they exercise their authority. The Commission must compel the Sheriff's Department to release the unredacted MOU and enforce absolute compliance with the Missouri Sunshine Law (Chapter 610, RSMo). A community cannot self-govern when the administrators tasked with enforcing the law systematically refuse to disclose their own operational frameworks.
CLICK HERE TO SEE YOUR RAY COUNTY COMMISSIONERS

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