Charles Francis Williams v. State
06-15-00030-CR
| Tex. App. | Dec 1, 2015Background
- Surveillance video at Sharyland Utilities shows two men stealing items and loading spools of copper wire into a marked Sharyland meter truck; one wore a light-blue shirt and carried bolt cutters, the other wore a dark-blue shirt and drove the meter truck away after an alarm sounded.
- The meter truck had GPS tracking; officers traced it to property of Katie Brown, where they found the stolen meter truck, Williams, and Stankiewicz.
- A Ford Ranger at the location (driven by Williams) contained bolt cutters, tools, and the light-blue shirt seen on the surveillance video; the missing copper wire was not recovered but valued at ~$180.
- Williams was identified on the video by multiple officers and admitted arriving at Brown’s house with Stankiewicz; he pleaded true to enhancement paragraphs and was convicted by a jury of theft (< $20,000) and sentenced to 10 years’ imprisonment.
- On appeal Williams argued insufficient evidence because he was not shown in direct possession of the copper wire; the Court reviewed the sufficiency of the evidence under Jackson/Brooks standards and party-liability principles.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Williams) | Held |
|---|---|---|---|
| Sufficiency of evidence to convict Williams of theft | Surveillance, identification, tools/shirt in Williams’ vehicle, admissions establish participation as a party to theft | Lack of direct possession of the stolen copper wire means insufficient evidence | Conviction affirmed: evidence legally sufficient to show Williams was a party to the theft |
Key Cases Cited
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard for reviewing legal sufficiency of evidence under Jackson)
- Jackson v. Virginia, 443 U.S. 307 (1979) (constitutional sufficiency-of-evidence standard)
- Hartsfield v. State, 305 S.W.3d 859 (Tex. App.—Texarkana 2010) (application of sufficiency review principles)
- Hooper v. State, 214 S.W.3d 9 (Tex. Crim. App. 2007) (jury’s role in weighing evidence and drawing inferences)
- Clayton v. State, 235 S.W.3d 772 (Tex. Crim. App. 2007) (deference to jury fact-finding in sufficiency review)
- Malik v. State, 953 S.W.2d 234 (Tex. Crim. App. 1997) (definition of hypothetically correct jury charge for sufficiency analysis)