IN THE CIRCUIT COURT OF ST.

LOUIS COUNTY
STATE OF MISSOURI

-VS-

MICHAEL HONKOMP RACE: White SSN: -

SEX: Male OCN:
Florissant, MO 63031 DOB: 04/26/1989 CASE ID: 189413850
HGT: 5'08” RPT NO: 20-1165
Aliases: WGT: 167lbs. CT. NO:
P.D.: Maryland Heights
Defendant ORI Number: MO0950H00

CHARGES
Count: 01 MURDER 1ST DEGREE - CLASS A FELONY
Count: 02 ARMED CRIMINAL ACTION - CLASS U FELONY
Count: 03 ASSAULT 1ST DEGREE OR ATTEMPT - SERIOUS PHYSICAL INJURY OR SPECIAL VICTIM - CLASS A
FELONY
Count: 04 ARMED CRIMINAL ACTION - CLASS U FELONY
Count: 05 RESISTING/INTERFERING WITH ARREST FOR A FELONY - CLASS E FELONY
Count: 06 ARMED CRIMINAL ACTION - CLASS U FELONY

COMPLAINT

State of Missouri )
SS (HOLD FOR GRAND JURY)
County of St. Louis )

Comes now the undersigned complainant, being duly sworn upon oath, and under penalties of perjury, and states
that there is probable cause to believe that the above-named defendant committed the following crime(s):

COUNT: 01 MURDER 1ST DEGREE - CLASS A FELONY

That Michael Honkomp, in violation of Section 565.020, RSMo, committed the class A felony of
murder in the first degree punishable upon conviction under Section 565.020, RSMo, in that on or
about on or about February 24, 2020, in the County of St. Louis, State of Missouri, the defendant
after deliberation, knowingly caused the death of Maria Lucas by shooting her.

565.020-001Y19840999.0

COUNT: 02 ARMED CRIMINAL ACTION - CLASS U FELONY

That Michael Honkomp, in violation of Section 571.015, RSMo, committed the felony of armed criminal
action, punishable upon conviction under Section 571.015.1, RSMo, in that on or about February 24,
2020, in the County of St. Louis, State of Missouri, the defendant committed the felony of murder in
the first degree charged in Count One, all allegations of which are incorporated herein by reference,
and the defendant committed the foregoing felony of murder in the first degree, by, with and through,
the knowing use, assistance and aid of a deadly weapon.

571.015-001Y19755299.0
COUNT: 03 ASSAULT 1ST DEGREE OR ATTEMPT - SERIOUS PHYSICAL INJURY OR SPECIAL VICTIM - CLASS
A FELONY

That Michael Honkomp, in violation of Section 565.050, RSMo, committed the class A felony of assault
in the first degree of a special victim, punishable upon conviction under Section 558.011, RSMo, in
that on or about February 24, 2020, in the County of St. Louis, State of Missouri, the defendant
repeatedly shot at Officer Jerrod, and such conduct was a substantial step toward the commission of
the offense of assault in the first degree of Officer Jerrod, a law enforcement officer in the
performance of his official duties, and was done for the purpose of committing such assault.
565.050-001Y19841399.0

COUNT: 04 ARMED CRIMINAL ACTION - CLASS U FELONY

That Michael Honkomp, in violation of Section 571.015, RSMo, committed the felony of armed criminal
action, punishable upon conviction under Section 571.015.1, RSMo, in that on or about February 24,
2020, in the County of St. Louis, State of Missouri, the defendant committed the felony of assault in
the first degree of a special victim, charged in Count Three, all allegations of which are incorporated
herein by reference and the defendant committed the foregoing felony of assault in the first degree
of a special victim by, with and through, the knowing use, assistance and aid of a deadly weapon.
571.015-001Y19755299.0

COUNT: 05 RESISTING/INTERFERING WITH ARREST FOR A FELONY - CLASS E FELONY

That Michael Honkomp, in violation of Section 575.150, RSMo, committed the class E felony of
resisting an arrest, punishable upon conviction under Sections 558.002 and 558.011, RSMo, in that
on or about February 24, 2020, in the County of St. Louis, State of Missouri, Officer Jerrod, a law
enforcement officer, was making an arrest of defendant for murder in the first degree, and the
defendant knew that the officer was making an arrest, and, for the purpose of preventing the officer
from effecting the arrest, resisted the arrest of defendant by using or threatening the use of violence
or physical force in that defendant repeatedly shot at Officer Jerrod.
575.150-001Y20174899.0

COUNT: 06 ARMED CRIMINAL ACTION - CLASS U FELONY

That Michael Honkomp, in violation of Section 571.015, RSMo, committed the felony of armed criminal
action, punishable upon conviction under Section 571.015.1, RSMo, in that on or about February 24,
2020, in the County of St. Louis, State of Missouri, the defendant committed the felony of resisting
arrest charged in Count Five, all allegations of which are incorporated herein by reference,
committed the felony of resisting arrest and the defendant committed the foregoing felony of
resisting arrest by, with and through, the knowing use, assistance and aid of a deadly weapon.
571.015-001Y19755299.0

The undersigned Prosecutor informs the Court on information and belief that the above offense(s) herein charged
were committed.

/s/ Sheila Whirley

Sheila Whirley, MBE 51516
Assistant Prosecuting Attorney
Date

Ct. No. Div. Circuit Court of St. Louis County, Missouri