Jurisdiction Ruling Moves Richards Murder Case to Churchill County

The murder case against Robert Matthew Richards, accused of killing 25-year-old Sara Filiatraut in March 2024, is now proceeding in Churchill County after a district court judge dismissed the Lyon County case for lack of jurisdiction.

The order by Third Judicial District Court Judge Leon Aberasturi was filed Aug. 3, concluding that there was no forensic evidence establishing that the murder occurred in Lyon County rather than Churchill County, where Filiatraut’s body was found.

A new criminal complaint charging Richards with Open Murder was filed July 23 in New River Township Justice Court in Fallon. The complaint alleges Richards killed Filiatraut by strangulation, blunt force trauma, or both. Richards was arraigned on Aug. 6, and a status hearing scheduled Aug. 20 was continued to Oct. 1. 

The jurisdictional dispute originated earlier this year. At a status hearing March 30 in Third Judicial District Court in Yerington, Aberasturi set a criminal settlement conference for July, and a trial date of Oct. 27 through Nov. 6 if the matter was not resolved.

However, at that hearing, attorney Kale Brock, representing Richards, told the court the defense intended to seek a change of venue to transfer the case to another county. On May 7, the defense filed a Motion to Dismiss for Lack of Jurisdiction, contending the state had no proof establishing where or when Filiatraut died, meaning the crime could have occurred in either county.

Aberasturi heard arguments on the motion to dismiss on July 14. 

Filiatraut was reported missing April 15, 2024, by her father in Michigan, who said she had not contacted him in many weeks. He told investigators she did not have a cellphone and would borrow phones and computers from others to communicate. 

Filiatraut’s family in Michigan reported that her last known location was in Lyon County on March 21, 2024. That’s the day she was released from jail after an arrest on charges of possession of drug paraphernalia.

Lyon County Sheriff’s Office (LCSO) investigators determined that after being released from jail, Filiatraut traveled to Fernley, where she used an acquaintance’s phone. LCSO said her social media activity stopped completely after March 22, 2024.

According to the Findings of Fact detailed in the court order, Richards and Filiatraut conversed on March 22, 2024, about going to a casino. Through search warrants, the Sheriff’s Office was able to verify that Richards and Filiatraut met.

Deputies found video that showed a woman who resembled Filiatraut getting into a truck that resembled Richards’ truck near McDonald’s on March 22. Video showed Richards going into Raley’s shortly after being seen near McDonald’s. 

Location data showed Richards’ vehicle went to a local casino and then back to his residence, where it remained until the next morning, March 23, 2024. 

A surveillance camera at the Fox Peak gas station captured a picture of Richards’ truck on the morning of March 23, 2024. Filiatraut was not visible in the truck.

The location data then tracked the truck into a desolate area of Churchill County.

Richards told investigators he knew Filiatraut and said he had spent time with her on three occasions. He claimed their last meeting was March 22, 2024, and that she had left after showering at his trailer.

On May 20, 2024, investigators from Lyon and Churchill counties searched the desert area where Richards’ truck had traveled, discovering Filiatraut’s body in a remote desert pit about 30 miles east of Fallon.

Investigators documented one set of vehicle tracks going in and out of the area, along with drag marks leading from where the vehicle appeared to stop to where the body was found. Phone location records placed Richards within five meters of where the body was found.

The Lyon County District Attorney’s Office argued that Lyon County was the appropriate venue for the case because the location records indicated that Filiatraut was at Richards’ residence the night before his truck traveled to the site where her body was found.

The prosecution argued that the circumstantial evidence met the preponderance of the evidence standard to establish that Filiatraut was killed in Lyon County and her body was disposed of in Churchill County.

The defense argued that the state presented no forensic evidence as to where the act of murder occurred and that without forensic evidence concerning location or time of death, the location could be either Lyon or Churchill County.

In his ruling, Aberasturi cited a 2021 case, Martinez Guzman v. Second Judicial District Court, which he said requires the state to “present some modicum of nonspeculative evidence that some act of murder occurred in Lyon County since the body was found in a different county.”

The judge also referenced the 1962 ruling in Walker v. State, in which Paul Allison, driving a pickup truck through Elko, picked up Walker, who was hitchhiking. They later stopped in Lovelock, and at some point Walker stabbed Allison during a fight. Allison was found dead in the pickup camper in a parking lot in Reno. 

“The Court finds the facts and holding in Walker provide a safe harbor for a conclusion that venue is proper in Churchill County, as the Guzman opinion did not expressly overrule Walker,” Aberasturi’s ruling states.