Arthur James Williams v. State
12-15-00017-CR
| Tex. App. | Dec 4, 2015Background
- Appellant Arthur James Williams was convicted of burglary of a habitation; he appealed claiming the evidence was legally insufficient.
- Police responded to an alarm around 10:00 p.m.; Detective Heavner located appellant inside the complainant’s locked garage holding tools and forced the garage door open to detain him.
- Homeowner Ms. Morris testified the garage had been alarmed and locked that evening, no one had permission to enter, and tools belonging to her husband were missing from the garage.
- The morning after the incident, several tools were found piled in a garden cart moved near the hedge; Ms. Morris identified them as her husband’s electrical and woodworking tools.
- The State argued the combined evidence (alarm, locked door, appellant inside with tools at night, displaced tools in a cart) proved entry without consent and intent to commit theft, satisfying burglary elements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for burglary of a habitation | State: Evidence (alarm, locked garage, defendant inside at night with complainant’s tools, displaced tools in cart) supports conviction | Williams: Evidence insufficient; appellant’s intent to steal not proven beyond conflicting testimony about pry marks and intent | Court: Evidence legally sufficient; reasonable inferences support burglary conviction |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of the evidence)
- Clayton v. State, 235 S.W.3d 772 (deference to factfinder and reviewing sufficiency)
- Acosta v. State, 429 S.W.3d 621 (sufficiency review principles)
- Brown v. State, 270 S.W.3d 564 (factfinder as sole judge of credibility)
- Dewberry v. State, 4 S.W.3d 735 (appellate courts cannot reweigh evidence)
- Hooper v. State, 214 S.W.3d 9 (consider cumulative force of all evidence)
- Chambers v. State, 805 S.W.2d 459 (factfinder may accept or reject witness testimony)
