Yanez, an officer with the St. Anthony Police Department, was charged with manslaughter in connection to 32-year-old Castile's July 6 death. His attorneys argue Yanez did everything correctly when he pulled Castile over, and his actions were justified because Castile reached for his gun, the memo says.
According to the memo, Yanez described what the gun looked like in a statement the day after the shooting, with the defense noting the gun that fell out of Castile's pocket matched the description Yanez gave.
The charges filed against Yanez in November include accounts of interviews he gave right after the shooting.
He told a fellow St. Anthony police officer he ordered Castile not to reach for the gun, but noted Castile “had his, his grip a lot wider than a wallet." Yanez also said he didn't know where the gun was, but was nervous.
The next day he told a Bureau of Criminal Apprehension investigator Castile had turned his body in the car and Yanez couldn't see what he was doing with his hand.
"It was dark inside the vehicle. I was trying to fumble my way through under stress to look and see what it was to make sure uh what I was seeing. … But I, I know he had an object and it was dark. … And as he was pulling it out I, a million things started going through my head. And I thought I was gonna die," Yanez said.
The 13-page memo also argues against the state's case that Yanez incorrectly conducted the traffic stop. You can read the memo here.
The defense filed a motion in December to get the case against Yanez dismissed, and prosecutors in January filed a rebuttal to that motion. The memo filed Tuesday was in response to the state's rebuttal.
A judge will rule on the defense's dismissal request on Feb. 15, the Pioneer Press notes.