The Judge Holmes murder took place during Lucifer's trial for the murder of two gunmen after the interview shooting. During the trial, Lucifer clicked her fingers, arguing that this was not a crime. However, when she did so, Judge Holmes' head exploded, killing him. Lucifer was imprisoned for this crime, leading to the events of the Faust Act. In reality, the murder was committed by Ananke, who was watching the trial from afar with Woden by scrying through Amaterasu's jewellery.