State v. WilliamsAnnotate this Case
When Defendant and two accomplices attempted to rob Michael Parker, Parker and a houseguest, Authur Robinson, were shot and killed. During trial, the jury was instructed that it could convict Defendant of the felony murder of the Robinson if the defendants had attempted to rob Robinson and the attempted robbery caused Robinson’s death. The State, however, presented insufficient evidence that the defendants had attempted to rob Robinson. The jury convicted Defendant of felony murder in Robinson’s death even though it found Defendant not guilty of the attempted robbery of Robinson. A valid theory of felony murder for the death of Robinson would be that Defendant, as a party to the crime, caused the death of Robinson while engaged in an attempted armed robbery of Parker. The Supreme Court affirmed Defendant’s convictions, holding (1) a jury instruction may be considered erroneous when it describes a theory of criminal culpability that was not presented to the jury or it omits a valid theory of criminal culpability that was presented to the jury; and (2) the defect in the jury instructions in this case was harmless error.