STATE OF MISSOURI

VS
Barnes, Willie James
CA#: 510666800

DIV #:
CAUSE#:
DESTINATION: GRAND JURY
DEFENDANT INFORMATION
ADDRESS: 14XX N 9TH ST
Saint Louis, MO 63106
PEDIGREE: RACE: B
DOB: XX/XX/1965
HGT: 5'07"
SEX: M
AGE: 49
WGT: 240
ID #s:
COMPLAINT#: 15002195
LID: 216320
ARREST#: 3150000804
DIST: SLMPD
OCN:
ALIASES:
SSNs: XXX-XX-XXXX
XXX-XX-XXXX
STATE OF MISSOURI )
CITY OF ST. LOUIS
)SS

COMPLAINT

The Circuit Attorney of the City of St. Louis, State of Missouri, upon information and belief,
charges that
Count 1:
Murder 1st Degree (Class A FELONY) RSMo 565.020
ON 1/15/2015 Time: Place: 10XX S TUCKER BLVD

(SCC 10021)

The defendant, 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 January
15, 2015, in the City of St. Louis, State of Missouri, the defendant after deliberation, knowingly caused
the death of C.S. by shooting her.

Count 2:
Armed Criminal Action
S TUCKER BLVD

(FELONY) RSMo 571.015 ON 1/15/2015 Time: Place: 10XX

(SCC 31010)

The defendant, 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 January 15,
2015, in the City of St. Louis, State of Missouri, the defendant committed the felony of Murder 1st
Degree charged in Count I, all allegations of which are incorporated herein by reference, and the
defendant committed the foregoing felony of Murder 1st Degree by, with and through, the knowing use,
assistance and aid of a deadly weapon.

Count 3:
Assault 1st Degree - Serious Physical Injury
(Class A FELONY) RSMo 565.050
ON 1/15/2015 Time: Place: 10XX S TUCKER BLVD
(SCC 13011)

The defendant, in violation of Section 565.050, RSMo, committed the class A felony of assault in
the first degree, punishable upon conviction under Section 558.011, RSMo, in that on or about January
15, 2015, in the City of St. Louis, State of Missouri, the defendant attempted to cause serious physical
injury to M.Y. by shooting him, and such conduct was a substantial step toward the commission of the
crime of attempting to cause serious physical injury to M.Y., and was done for the purpose of committing
such assault, and in the course thereof inflicted serious physical injury on M.Y.

Count 4:
Armed Criminal Action
S TUCKER BLVD

(FELONY) RSMo 571.015 ON 1/15/2015 Time: Place: 10XX

(SCC 31010)

The defendant, 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 January 15,
2015, in the City of St. Louis, State of Missouri, the defendant committed the felony of Assault 1st
Degree charged in Count III, all allegations of which are incorporated herein by reference, and the
defendant committed the foregoing felony of Assault 1st Degree by, with and through, the knowing use,
assistance and aid of a deadly weapon.

Count 5:
Discharge/shoot Firearm At Or From Motor Vehicle/shoot At Person, Another Motor
Vehicle, Or Building/habitable Structure - Prior Offender
(Class A FELONY) RSMo 571.030
ON 1/15/2015 Time: Place: 10XX S TUCKER BLVD
(SCC 31149)
The defendant, in violation of Section 571.030, RSMo, committed the class A felony of unlawful
use of a weapon, punishable upon conviction under Sections 558.011 and 571.030.9, RSMo, in that on
or about January 15, 2015, in the City of St. Louis, State of Missouri, the defendant, knowingly shot a
firearm from a Chevy suburban, a motor vehicle, and as a result of the above described conduct, C.S.
suffered injury or death.

The facts that form the basis for this information and belief are contained in the attached
statement(s) of facts, made a part hereof and submitted as a basis upon which this court may find the
existence of probable cause.

Wherefore, the Circuit Attorney prays that an arrest warrant be issued as provided by law.
Jennifer M. Joyce
Circuit Attorney of the City of St. Louis,
State of Missouri
By (Original Signed)
Assistant Circuit Attorney

PROBABLE CAUSE STATEMENT

DATE: January 16, 2015

I, Keith Paulitsch, knowing that false statements on this form are punishable by law, state that the
facts contained herein are true.
1. I have probable cause to believe that Willie James Barnes, a Black Male DOB: XX/XX/65 Age: 49,
committed one or more criminal offense(s).
Count 1:
Murder In The First Degree
(Class A FELONY) RSMo 565.020
ON 1/15/2015 Time: Place: 10XX S TUCKER BLVD
(SCC 10021)
Count 2:
Armed Criminal Action
(FELONY) RSMo 571.015
ON 1/15/2015 Time: Place: 10XX S TUCKER BLVD

(SCC 31010)

Count 3:
Assault In The First Degree - Serious Physical Injury (Class A FELONY) RSMo
565.050
ON 1/15/2015 Time: Place: 10XX S TUCKER BLVD
(SCC 13011)
Count 4:
Armed Criminal Action
(FELONY) RSMo 571.015
ON 1/15/2015 Time: Place: 10XX S TUCKER BLVD

(SCC 31010)

Count 5:
Shoot Firearm At Mv/pers/bldg-prior
(Class A FELONY) RSMo 571.030
ON 1/15/2015 Time: Place: 10XX S TUCKER BLVD
(SCC 31149)
2. The facts supporting this belief are as follows:
The defendant and the victim, C.S., had been in a romantic relationship and shared a child in
common. On the morning of January 15, 2015 around 8 a.m., C.S. was driving her car with her
current boyfriend in the front passenger seat. The defendant began following C.S. in his Suburban as
they traveled through traffic. The defendant was gesturing for C.S. to pull over. When C.S. failed to
pull over for the defendant, the defendant continued to follow her until they reached the stoplight at
Chouteau and Tucker. The defendant rolled down his window and exchanged words with C.S. The
defendant then fired several shots at C.S. from the defendants Suburban, striking her in her shoulder
and chest. C.S. died as a result of the gunshot wounds. C.S.s boyfriend was also struck in the
hands as a result of the defendant firing into the victims car. As of todays date, C.S.s boyfriend was
undergoing surgery to repair the wounds to his hands.
This incident occurred during peak downtown traffic. The defendant left the scene immediately after
the shooting, and was taken into custody within 90 minutes of the incident. Police recovered a .38
special revolver from the defendant, which is believed to be the murder weapon.
Keith Paulitsch
PRINT NAME
I believe the defendant has the following criminal history:
rd

12/04/1997 Assault 3 Degree (St. Louis City) -- SIS

(Original Signed)
SIGNATURE