Chiefs Rally Shooting Charging Documents
Chiefs Rally Shooting Charging Documents
CIRCUIT COURT OF
JACKSON COUNTY, MO
IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI
AT KANSAS CITY
STATE OF MISSOURI, )
PLAINTIFF, )
vs. )
)
DOMINIC M MILLER )
7700 E 111TH TER ) CASE NO. 2416-CR
KANSAS CITY, MO 64134 ) DIVISION
DOB: )
Race/Sex: B/M )
S.S.N.: )
DEFENDANT. )
AMENDED COMPLAINT
WARRANT REQUESTED
Count I. Murder 2nd Degree - Felony Murder - During Perpetration/Attempted
Perpetration/Flight From Perpetration Of A Felony, A Person Dies (565.021-
003Y20200999.0)
An individual convicted and sentenced for this offense shall not be eligible for parole until
eighty-five percent of the sentence is served.
The range of punishment for a class A felony is imprisonment in the custody of the
Missouri Department of Corrections for a term of years not less than ten (10) years and not
to exceed thirty (30) years, or life imprisonment.
State vs. DOMINIC M MILLER, Case No.
Count III. Unlawful Use Of Weapon - Subsection 9 - Shoot At/From Motor Vehicle,
At Person, Motor Vehicle Or Building (571.030-020Y20205213.0)
The range of punishment for a class B felony is imprisonment in the custody of the
Missouri Department of Corrections for a term of years not less than five (5) years and not
to exceed fifteen (15) years.
State vs. DOMINIC M MILLER, Case No.
The facts that form the basis for this information and belief are contained in the
statement(s) of facts filed contemporaneously herewith, made a part hereof, and submitted
as a basis upon which this court may find the existence of probable cause.
WITNESSES:
The State’s witnesses as of 2/20/2024 are included on the “State’s Witness List” filed
contemporaneously with this Amended Complaint.
PROBABLE CAUSE STATEMENT FORM
Date: 02-16-2024 CRN: KC24009897
knowing that false statements on this form are punishable by law, state that the facts contained herein are true.
I have probable cause to believe that on 02-14-2024 , at Pershing Road and Kessler Road in
(Date) (Address)
On 02-14-2024, Officers with the Kansas City, Missouri Police Department were working at the Kansas City
Chiefs Super Bowl parade, located at 30 West Pershing Road, Kansas City, Jackson County, Missouri 64108.
At approximately 1349 hours, Officers responded to sounds of shots in the area of Pershing Road and Kessler
Road Kansas City, Jackson County, Missouri. Officers located multiple victims, one being deceased, suffering
from apparent gunshot trauma and as a result, a homicide investigation was initiated.
An individual, later identified as Dominic Miller, was located suffering from apparent gunshot trauma in the
center median of Pershing Road, just east of Kessler Road after a witness flagged Officers down. The witness
told Officers he observed Miller running eastbound after the sound of gunshots and he heard him shouting,
“I’m Shot, I’m shot.” The witness further observed Miller carrying a black firearm near his waistband as he
was running, so he tackled him and took the firearm from him. The firearm (black Taurus G3 9mm, S/N-
ADD238968) was located in close proximity to Miller and it was guarded by the witness until he was able to
alert Officers. Miller was transported to the medical tent located at the southwest corner of Union Station
property by emergency medical personnel who utilized a red wagon to transport him. Medical personnel
located a firearm magazine loaded with live ammunition in the red wagon used to transport Miller which was
recovered by Officer at the scene. Miller was transported from the scene to University Hospital for further
medical treatment.
On 02-15-2024, Detectives responded to KU Medical Center to interview a subject being treated for gunshot
injuries sustained during the shooting at Union Station. During the interview with the subject, he stated he was
at the parade with Miller when the shooting occurred and he believed Miller had been shot in the abdomen
after hearing the information through social media. The subject stated Miller was wearing a red Calvin Klein
zip up hoodie and a red Chiefs Super Bowl Champs jersey. The subject stated Miller was trailing behind him
before the shooting started and he did know where he went during or after the shooting because he took off
running westbound after he got shot. The subject stated he did not see anyone else armed with a gun other than
the person that shot him.
Page 1 of 3
Form 50 P.D. (Rev. 9-2008)
PROBABLE CAUSE STATEMENT FORM
CRN KC24009897
gunshots, he observed a black male with dreads armed with a black handgun shooting at him. Miller stated he
returned fire with his own firearm. Miller estimated he fired 4-5 shots and was uncertain if he struck the
individual he was shooting at. Miller claimed he did not see anyone else armed at the time of the shooting.
During the autopsy of the female victim, a 38 caliber class bullet was recovered from her body. A ballistic
comparison of the bullet recovered from the female victim and the firearms recovered in relation to the
homicide was conducted and it was determined the bullet recovered from the female was fired from the Taurus
G3 9mm, the firearm Miller acknowledged possessing and firing.
Printed Name Dective Brian Cowan #5114 Signature /s/Detective Brian Cowan #5114
The Court finds probable cause and directs the issuance of a warrant this day of .
Judge
Page 3 of 3
Form 50 P.D. (Rev. 9-2008)
17-Feb-2024 13:47
CIRCUIT COURT OF
JACKSON COUNTY, MO
IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI
AT KANSAS CITY
STATE OF MISSOURI, )
PLAINTIFF, )
vs. )
)
LYNDELL MAYS )
10103 E 67TH ST ) CASE NO. 2416-CR
RAYTOWN, MO 64133 ) DIVISION
DOB: )
Race/Sex: B/M )
S.S.N.: )
DEFENDANT. )
COMPLAINT
WARRANT REQUESTED
Count I. Murder 2nd Degree - Felony Murder - During Perpetration/Attempted
Perpetration/Flight From Perpetration Of A Felony, A Person Dies (565.021-
003Y20200999.0)
An individual convicted and sentenced for this offense shall not be eligible for parole
until eighty-five percent of the sentence is served.
The range of punishment for a class A felony is imprisonment in the custody of the
Missouri Department of Corrections for a term of years not less than ten (10) years and not
to exceed thirty (30) years, or life imprisonment.
State vs. LYNDELL MAYS, Case No.
Count III. Unlawful Use Of Weapon - Subsection 9 - Shoot At/From Motor Vehicle,
At Person, Motor Vehicle Or Building (571.030-020Y20205213.0)
The range of punishment for a class B felony is imprisonment in the custody of the
Missouri Department of Corrections for a term of years not less than five (5) years and not
to exceed fifteen (15) years.
State vs. LYNDELL MAYS, Case No.
The facts that form the basis for this information and belief are contained in the
statement(s) of facts filed contemporaneously herewith, made a part hereof, and submitted
as a basis upon which this court may find the existence of probable cause.
WITNESSES:
The State’s witnesses as of 2/17/2024 are included on the “State’s Witness List” filed
contemporaneously with this Complaint.
PROBABLE CAUSE STATEMENT FORM
Date: 02-17-24 CRN: KC24009897
knowing that false statements on this form are punishable by law, state that the facts contained herein are true.
I have probable cause to believe that on 02-14-24 , at West Pershing Road & Kessler Road in
(Date) (Address)
Felony Murder
Armed Criminal Action
On 02-14-24, officers with the Kansas City, Missouri Police Department were working at the Kansas City
Chief's Super Bowl Parade, located at 30 West Pershing Road, Kansas City, Jackson County, Missouri 64108.
At approximately 1349 hours, officers responded to sounds of shots near West Pershing Road & Kessler Road.
Twenty-Five victims, suffering from apparent gunshots wounds, were either located at the scene or at area
hospitals. A 43-year-old female, who was among these victims, succumbed to her injuries and her death has
been ruled a homicide by the Jackson County Medical Examiner’s Office.
An individual, later identified as Lyndell Mays, was located suffering from apparent gunshot trauma, just to the
north of West Pershing Road & Kessler Road. A pistol was located next to Lyndell Mays, as well as, spent
shell casings. Lyndell Mays was transported to an area hospital for treatment.
Witness 9 was present at the time of the shooting. She responded to Police Headquarters, 1125 Locust Street,
Kansas City, Missouri 64106, to give a statement. She stated herself and Lyndell Mays were at Kessler Road
& Pershing Road. She stated a group of four males approached Lyndell Mays and one of the males asked
Lyndell Mays what he was looking at, because they didn’t know him. Lyndell Mays told Witness 9 he did not
know who the individuals in the group were. Witness 9 stated one of the individuals had a backpack with a
firearm hanging out of it. According to Witness 9, the two individuals pulled out firearms from their
backpacks. Witness 9 tried to pull Lyndell Mays away so they could leave. As she turned her back, she heard
gunshots. When she turned back around, she saw the group shooting at Lyndell Mays. She clarified and stated
the incident happened fast and she only saw the individuals with their firearms out, but could not see who was
shooting. After the individuals started shooting at Lyndell Mays, Lyndell Mays pulled out his own pistol and
started returning fire. Witness 9 started to run away, and when she looked back at Lyndell, she observed him
fall to the ground. She ran to Lyndell Mays and observed him suffering from apparent gunshot trauma. A still
photo, from surveillance video at the scene, was shown to Witness 9. Witness 9 positively identified Lyndell
Mays by circling him on the photo and writing “Lyndell.” Witness 9 positively identified herself by circling
Page 1 of 3
Form 50 P.D. (Rev. 9-2008)
PROBABLE CAUSE STATEMENT FORM
CRN KC24009897
herself and writing “me.” Lyndell Mays was observed wearing a red long-sleeved shirt. Witness 9 was
observed wearing a white long-sleeved shirt.
Detectives interviewed Witness 9’s boyfriend (Witness 13). He stated a group of individuals approached
Lyndell Mays and Witness 9 and they began arguing about why they were staring at each other. One of the
individuals had a backpack and he could see a firearm inside it. Witness 13 stated at no time did the individual
touch the firearm or make any threatening statements. Witness 13 also stated none of the individuals in the
approaching group made threatening statements to him, Witness 9, or Lyndell Mays.
Detectives reviewed surveillance video and observed Lyndell Mays and Witness 9 standing near the West
Pershing Road & Kessler Road intersection, just to the north. It appears Lyndell Mays gets into a verbal
confrontation with a group of individuals standing several feet away from them. Lyndell Mays starts to
approach the individuals in an aggressive manner, at which time Witness 9 puts her hand on Lyndell Mays in
an attempt to stop him from advancing further. It appears Witness 9 and Lyndell Mays continue to verbally
argue with the individuals in the group. Lyndell Mays backs up and appears to continue yelling at the
individuals in the group, pointing his finger at them in an angry manner. Lyndell Mays circles behind a person,
and pulls out a handgun with his right hand and points it at one of the individuals (later identified as . At
this time, none of the other individuals appear to have produced a firearm. As Lyndell Mays is chasing
while pointing his gun at him, the other individuals in the group pull out their firearms and point them in the
direction of Lyndell Mays and appear to start shooting in his direction. ., whom Lyndell Mays is pointing
his gun at, is seen running away from Lyndell Mays and appears to be unarmed. Lyndell Mays continues to
chase as he is running away from him, and Lyndell Mays appears to be shooting at Lyndell Mays
then appears to get struck by gunfire and falls to the ground. The individuals involved flee the area. Witness 9
runs up to Lyndell Mays and immediately strikes him with her fist, in an angry manner, two times. Just to the
north of Lyndell Mays, the deceased victim is observed laying on the ground suffering from apparent gunshot
trauma. was transported to an area hospital with apparent gunshot trauma behind his left ear and his left
ankle.
On 02-16-24 at approximately 2056 hours, detectives interviewed Lyndell Mays at an area hospital. Lyndell
Mays was read his Miranda Rights, from Form 72 P.D. and he agreed to give a statement. Lyndell Mays stated
he, Witness 9, and Witness 13 were at the parade near Pershing Road and Kessler Road. Lyndell gave a
statement of what occurred that was inconsistent with surveillance video at the scene. When Lyndell Mays was
confronted that we had surveillance video of the incident, he then changed his story.
Lyndell Mays identified himself, Witness 9, and the others involved by circling them in a still shot taken from
the surveillance video. Lyndell Mays acknowledged he pulled out his gun first and began firing his gun at the
others first. Lyndell Mays was shown a still photo from surveillance video of him pointing a gun at one of the
individuals. When asked what that individual was doing, who he was pointing the gun at, Lyndell Mays stated
the individual was running away. Lyndell Mays stated he hesitated shooting because he knew there were kids
there. Lyndell Mays stated they all could have had guns so he just randomly picked one of the individuals to
target because he was in fear of Witness 9’s life. Lyndell Mays confirmed that he drew a gun first, in a crowd
of people with kids, picked one of the individuals in the group at random, and started shooting, all because they
said, “I’m going to get you” and to him, that meant, “I’m going to kill you.” Lyndell Mays stated the other
Page 2 of 3
Form 50 P.D. (Rev. 9-2008)
PROBABLE CAUSE STATEMENT FORM
CRN KC24009897
individuals started shooting only after Lyndell Mays shot first. Lyndell Mays initially stated he didn’t think he
shot his gun. When Lyndell Mays was advised he did shoot, he replied that he didn’t hit anything though, but
he knew it was still bad. Lyndell Mays then stated he only shot one (1) time. He then said maybe two (2)
times. When asked why Lyndell Mays advanced on them to begin with, he replied, “Stupid, man. Just pulled a
gun out and started shooting. I shouldn’t have done that. Just being stupid.” When reminded that the person
Lyndell Mays was shooting at was running away from him, Lyndell Mays replied, “I know.” Lyndell Mays
confirmed he shot first and shot two times. Lyndell Mays acknowledged he shouldn’t have pulled a gun out.
This incident occurred in the middle of a very large crowd of people who were there celebrating the Chiefs
Super Bowl Parade. At this time, there have been 25 victims injured by gunfire, resulting from this incident,
with one victim being fatally shot.
Detectives observed multiple 9mm and .40 caliber spent shell casings just north of the West Pershing Road &
Kessler Road intersection. A Glock 9mm handgun was observed on the ground, in apparent
blood, where Lyndell Mays fell on the ground after being shot. The magazine contained six (6) live 9mm
rounds in a 15-round capacity magazine. There was a live round in the chamber. A computer check revealed
the firearm to be stolen out of Kansas City, Missouri.
Printed Name /s/ Det. Grant Spiking #5484 Signature /s/ Det. Grant Spiking #5484
The Court finds probable cause and directs the issuance of a warrant this day of .
Judge
Page 3 of 3
Form 50 P.D. (Rev. 9-2008)