The dismissal of two criminal cases against firefighters are in the Fire Law News today, one in Texas, the other in Tennessee.
San Antonio Stalking Charge Dropped
In San Antonio, a third-degree felony stalking charge against Christopher Allen Steele — long-time president of the San Antonio Professional Firefighters Association — has been formally dismissed. Prosecutors confirmed they would not proceed with the case, and no current criminal charges remain.
Steele was arrested in mid-2024 following an investigation into a series of emails and text messages he allegedly sent to several San Antonio Fire Department employees, including then-interim Deputy Chief Valerie Frausto, during the city’s fire chief recruitment process. In the messages, he purported to be an “independent investigator” reporting alleged misconduct and warned that negative information would be made public unless the recipients responded. Investigators linked the communications to Steele through email accounts and telephone records.
The Bexar County District Attorney’s Office cited rulings by the Texas Court of Criminal Appeals — the state’s highest criminal court —which clarified that repeated communications alone, without other corroborating evidence of criminal intent or conduct, may not sustain stalking charges when the communications contain protected speech — as a key reason the case could not be proven beyond a reasonable doubt under the updated legal standard.
The Court of Criminal Appeals has held that when the alleged stalking “conduct” consists of solely of communications (emails, texts, messages), courts must analyze whether the communications constitute “true threats” as opposed to speech protected by the First Amendment. Speech that is offensive, aggressive, or unwanted is not automatically criminal. To support a stalking conviction, the communications must convey a serious expression of intent to commit unlawful violence or otherwise satisfy the statutory fear elements.
In practical terms, that means prosecutors must prove:
- The communications were objectively threatening (not merely critical, investigative, or accusatory);
- The complainant actually experienced qualifying fear; and
- A reasonable person in the same position would have experienced that fear.
With the dismissal, Steele’s criminal legal exposure on this matter has ended. More on the story.
Tennessee Firefighter Case Dismissed and Expunged
Last year we reported on a Tennessee firefighter charged with criminal impersonation, reckless driving, and violation of the emergency light statute after a reported road-rage incident in Cocke County in late December 2024.
According to charging documents, the firefighter, then 22, allegedly followed another driver on Cosby Highway, activated emergency lights and a siren on his personal vehicle, flashed what appeared to be a badge, and used a radio in a manner suggesting official authority — conduct that left the other motorist “terrified.” Here is more on the original story.
On February 26, 2026 the charges were summarily dismissed and the court ordered expungement of related records. Under Tennessee’s expungement statute, a dismissal — including after a plea, diversion, or nolle prosequi — can qualify the defendant for removal of public records, subject to statutory criteria. Here is the dismissal notice.
