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Aniended

faU Charge Prevrously Filed

/ifDomesdc Assault

deined by MS 518801, sub2a,b

State of Minnesota,
\/c
NAli4E: first, middle, iast S TEPH Ol { TERRELL SEt L}"${ ON
DEFEI{DANT,
4501 CAMDEN ST MN{N]EAPOLIS, }/N 5 54
11

PLAfNTIFF.,

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wenaaxr omsn oF DETENTToN exrnenrloN

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MI{CIS

Date of

Biith

7/) Alq<

LE#: SILS ID: TRACK ID:

#:

27-CP.12-20046

725466 2583766

COMPLAINT
The Complainurut, betng duly sv,orn, makes complaint ta the above-named Court and states that there is probable cause to beLieve that the Defendant committed thefollowing ofense(s). The complainani states thal thefollowingfacts establish PROBABLE CAUSE:

Complainant, Robert Dale, of the Minneapolis Police Department, has investigated the facts and circumstances of this offense and believes the follou'ing establishes probable cause:
On or about June 76,2012, at approximately 8:34 a.m., offrcers of the Minneapolis Police Department vsere dispatched to a residence located a|4515 Bryant Avenue North, Minneapolis, Henlepin County, Minnesota, upon report of a shootingthai had just occuned at that location. 'ihe report indicated that multiple shots had been fired into the home and a five year-old boy, N.A.G, date of birth 812lA6, had been shot. Upon entering the home, officers obsen,ed the victim iying lifeless on a sofa, with an apparent gunshot wound to his upper back area. Several other children and adults were crying. and told the ofrrcers ihat they heard gunshots lrom outside and then realized the viclim had been shot. Emergency medical care was summoned and the victim was transported to North Memorial Medical Center, but they could not save hrm, A later autopsy revealed the cause of death to be gunshot wound and the mamer of death, homicide.

Ofircers iocated ten discharged cartnd-ge casings outside the residence. The casings were located in two areas: a cluster in the middle of Bryant Avenue and a second set near the cwb in front of 451 5 and 45 i 9 Bryant Avenue North. Officers observed atleast one builet hole in a red Chewolet Blazer parked in lront of the residence. Officers located eight buliet strikes on the home, seven in the siding of the home and one on the railing of the fiont steps. Five of the builet strikes had penetrated into the living room's east wall. Two bullets penetrated the west wali of the living room. At least three buliet holes were obsened in the wails and doorframe of the northwest bedroom. Officers learned that three other children were sieeping on the couch with the victim at the time he was shoi and kiiled.

FORM-J

REV

12195

P *bzoe ^

TEPHON TERR-ELL

HAN

.rI

ON

CCN: 12196412

repofied heaing several gunshots and seeing tw'o people run from the scene after the shooting. Another witness reported seeing two individuals in front of 4575 Bryant Avenue North puil out handguns and shoot into the rrictim's residence. The witness, \\Iitness 1, said the witness knew one of the shooters, and that he had the street name "Furury \40." Witness 1 garre a descriplion of the other shooter. Witness I did not identily anyone in lrne
ups. 'Witness 2, who reported that the day before the murder, several young Officers also spoke to a knou':r indirridual, people u,ere at the neighborhood gas statiory'convenience store. The u'iiness saw someone he knelv as "Fumy N4o," point a gun at t$ro other teens. Other witnesses also told the ofhcers that the tw-o teens, who had been assaulted by "Furmy Mo," knew people at the victim's house and spent a iot of time there.

'W-itnesses

As officers canvassed the area for weapons or raritnesses, they were approached by residents of 4501 Camden Avenue Nor1h. The residents informed the officers that their house had been shot up at around midnight and that poiice had responded to the call and located discharged cartridge casings. Offlrcers could see approximately 5 bullet holes in the window glass. As they were taiking to the residences, lwo black maies, possibly in their early 20's, approached fiom the west and began arguing s'ith the residents of 450 i Camden Avenue North, accusing them of the shooting on Bryant Avenue North. Neighbors in the area told the officers of conflicts befween individuals ra'ho frequented the tll'o addresses. Cfficers spoke to known \\/itness 3, who had called police with inl'ormaiion about the identity of the shooters. 'Witness 3 reported that the witness had a conversation ra'ith STEPIION TERRELL SHAI\T{ON, date of birth 312411995, Defend,ant herein. Witness 3 told the officers that the witness spoke to Defendant, who admitted that he had shot into the victim's house. Defendant told the witness that he was on the porch area of 4501 Camden Avenue Noith u,hen it had been shot up by unknown individuals. Defendant was angry and believed people associated n'ith 45 i 5 Bryant Avenue North were responsible. Defendant went to the residence and fired into the house i.vith a handggn. Defendant told the witness that he had made his peace with God and was sorry about the baby.
Witness 3 attempted to get Defendant to turn himself in, but Defendant refused to do so because the poiice "didn't have nothin' on him." One June 27 ,2072, officers inierviewed a known juveniie, iater identihed as the Codefendant. He admitted being at the Camden address just prior to the house being shot up and returning to the residence shortly thereafter when poiice had responded to the call. The Codefendant said that some of the bullets peneh-ated into the porch area ghere he had just been sitting. The Codeiendant was confronted about reports that he was responsible for setting off the chain of events that lead to the murder of N.A.G. Officers told him that they kneu' he had pointed a gun at some guys at the local conrrenience store the night before, u'hich lead to the Camden address being shot up a:rd the retaiiatory shooting of the victim's home. The Codefendant initially denied his actions at the store, but later ad.mitted that he had "upped the gun" at the guys u'ho he had heard talking about how he was from the "other side." On June 28,2012, officers located both Defendant and Codefendani and arrested them. Defendant and Codefendant were seen leaving a hotel where they had been staying with the residents of 4501 Camden Avenue North. Defend,ant, Codefendant and another young man got into a velLicle registered to Jamica F{olden, one of the residents of the Camden home. As officers executed a search warrant for the hotel rooms rented by Holden's boyfriend, A:rtonio Ferguson, Ferguson told the others present not to talk to the police.

Pao..

STEPHON TERRELL

SHANNON

CCN

12196412

Defendant was interviewed afrer arights advisory and agreed to speak to investigators. Defendant was infonned thai he was in custody in connection u,ith the murder of N.A.G. and that a witness had told the officer that Defendant had confessed to shooting at the house. Defendant admitted speaking io the witness but denied that he had confessed to the killing. Defendant said he lived at 4501 Camden Avenue North and refen-ed to 'Mica', or Jamica Holden as his mother. Defendant said that he was on the front porch of 4501 Camden Avenue North on the ^ -rh rught of June 25"'when the house was shoi up. Defendant said that he knew who did it but would not teli the offrcers. Defendant said that he was a-Irgry ab,our the shooting and that several people were in the house when jt was shot up. Defendant denied being at the scene of victim N.A.G's murder. Defendairt berated the officers for lailing to solve the September 2011 murder of his "brothet" Juwan or "Skitz," Jamrca Holden's son. When officers stressed the impoitance of witness cooperation in solving homicides, Defendant said that if he kneu, rvho killed Juwan he would not tell the police, but would take care of it himsell later re-interviewed and said that the witness recognized "Funny \4o" in the lineup but did not identifl him because the w-itness was afraid of the shooters. Witness I identihed the known juveniie Codelendant in a line up as one of the individuais he saw shooting at the rrictirn's house. Witness 1 expressed concern over the witness's identity being disclosed and rhe potential for retaiiation.

Witness

1 was

The Codefendant was re-interviewed on June 28,2012, after being an-ested with Defendant. The Codefendant denied participating in shooting up the victim's house.

Offlcers also interviewed Jamica Holden, who confirmed that there irave been ongoing problems with violence and threats since the death of her son, Juwan. Juu'an's friends have been cailing themselves the "Skitz Squad," and spending a lot of time at her hou-se. Hoiden reported that people drive by the house and make threats to shoot up
'uhe house.

TE{E DEFENDANT trS 17 }|EARS OF AGE:

ACCOITDING TO htrhTq. STAT. $ 609.055, SIIBD. 2(b), $ 260.015, SUBD 5(b), AND IUII\T\'.R,IL\/.PROC. 18.S8, SUBD. 1, DEFEhIDANT SELAhT,{ON IS AUTOMATICALLY SUBIECT TO ABULT COITR.T .FURISDICTIOI'{.

Page

COMPLAIATT SUPFLEMENT
CCT SECTION/Subdivision

N,4na

GOC

OFFEI{SE

COIINT 1: AIDING AND ABETTiNG MUR}ER IN THE FIRST DEGREE (FELO}I9 Mn\N. STAT. $ 609.18s(a)(1); $ 609.11; $ 609.106, SLIBD.z(I); $ 609.0s PENALTY: LiFE
That on or about June 26, 2012, in Heiinepin Counly, Minnesot4 STEPEION TERRELL SFIANNON, acting alone or intentionally 2iditr*, advising, hinng, counseling or conspiring with another, and while using a firearm, caused the death of N.A.G., a human being, with premeditation and with intent to effect the death of that person, or another.

NOTICE: You must appear for every court hearing on this charge. A failure to appear for ccurt on this
charge is a criminal offense and may be punished as provided in Min-ir. Stat.
S 609.49.

TI{EREFOR-\, Complainant requests that said Defendant, subjeci to bofl or corzditions of release be r) arrested or that other lowfi.rl steps be taken to obtsin defendant's appearance in caurt; or 2) detained, if already in custody, pendingfurther proceedings; and that said Defendant atherwise be dealt v,ith accarding ta lata. CON,PLAiNANT'S SIGNATURE CON&LAINANT'S NAtrG:

Robert Dale
Being duly authorized to prosecate the affense(s) charged,
DATE.'

hereby crpprore this Complaint.

Y'S SIGNATURE:

Jttly
P

2,2412

cy
ADDRESS/TELEPHONE:

RO SEC UTN,IG ATTO RNEY. NAME/TITLE:

susAl"{ B CRUMB (148246} Assistant County Attorney

FOR.M I-2

Tetrephone

C2100 Government Center, Minneapolis, VfN 5548, : 6L2-348-56L2

Rev. 3/94

Page
Cora.t Case #

This COIT4PLANT was subscribed and srvorn io before the undersigned this

dzv nf *_/

20

NAI4E: TITLE:

SlGNATLRE:

FNDI{G

OF PROBABLE CAUSE

Frorn the above sworn facts, and a74t supporting ffidovits or supplemental sworn testimony, I, the Issuing Afficer, hcrpe determined that probable cause exists to support, subjectto bail or conditions ofreleosewhere applicable, Defendant(s) orrest or ather lowful sreprs be taken to obtain Defendatt(s) appe(nance in Caurt, or his delention, if alrea$t in cuslo$t, pending further proceedings. The Defendanr(s) is/are thereof charged with the above-stated ofense.

l
I

SUMMONS
TI{ER-EtrOR-E YOU, THE ABO\E-NA-LGD DEFENDANT(S), ARE FIEREBY SUVtr\4O}.iED to appear on the
day

of

AJvi,?M before the above-named court at ,20_at _ to answer thi.s complaint. IF YOU FAtr- TO APPEAR in response to this SIA&4ONS, a WARRAIIT FOR YOUR ARREST shail be issued.

To the sheriff of the above-named coluths; or other person authorized ta execute this WA-RR4I{T; I hereby order, in the name of the State of Mtinnesota, that the above-named Defendant(s) be apprehended and arrested wiihoui rielay and brou"ght prompt$t before the above-named Court (if in session, and if not, before a Judge or Judicial fficer of su-ch Court without unnecessary delay, anti tn atty event not later than 3 6 hours afier tlze arrest or as soon thereafier as such Judge or Judicial Officer is available) to be dealt with according to
117'W

smcurB

wARR.{NT
nq

ricnwnsorA GI{LY

;;

named Defendant(s) continue io be detoined pendingfurther proceedings. Bail: 52,000,000 + CR

Sn", the aboye-named Defet,tdant(s)

ORDER OF DETENTIOIq is alreaaJt in custody; I hereby order, subject

to bail or conditions of releose, ihat the above-

Conditions of Release; No eontact rrith s'itness(es); No contact with address; No eontact with co-defendant(s)

This CO\&LANTday Officer this

g,i#
oi

ORDER OF DETENTION

ffil

ddy subscribed and sworn to,

is issued by the uadersi-ned Judicial

,lv
SIG]TJATURE

NAME:

TITLE: JUDGE

OF DISTRICT COURT

Sworn testjmony has been given before the Judicial Offlcer by the following witnesses:

STATE OF MN$|ESOTA

COLINITY OF HE}N\TEPIN

CLerk's Signature or File Stamp;

S-r,eTg OF MIhINESCTA
Plaintiff
vs.

RETURN OF SERVICE I hereby Certify and Relurn that I have served a copy of this
CONIPLAN'iT

DETENTION upon Defendant(s) hereil-named. Signairre olAuthorized Sen.ice Agent:

UMM ON S, \A/AR-R*AI'IT, ORDER

STEPHO]\ TERRELL SHA]\TNON

Defendant(s).

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