Charles Francis Williams v. State
06-15-00031-CR
| Tex. Crim. App. | Oct 15, 2015Background
- Appellant Charles Francis Williams was convicted after a jury found him guilty of Theft of Copper and Unauthorized Use of a Motor Vehicle arising from an August 19, 2014 burglary of Sharyland Utilities.
- Surveillance video showed two white male intruders cutting a chain-link fence, taking copper wire (three 25-lb spools, valued at $180) and a meter-reader truck; one intruder wore a dark blue shirt, the other a light blue/teal shirt.
- Investigators identified Williams from the video; officers recovered a light blue/teal T-shirt, gloves, bolt cutters, hard hats, and the stolen truck concealed in a shed near Katie Brown’s residence, where Williams and co-defendant Frankie Stankowitz were located.
- The State charged Williams either as the principal or as a party under Texas Penal Code §7.02(a)(2) for acting with intent to promote or assist the offense.
- The Court of Appeals reviewed the sufficiency of the evidence under the Jackson v. Virginia standard (viewing evidence in the light most favorable to the verdict) and considered testimonial and unobjected-to hearsay evidence the jury relied upon.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legal sufficiency of evidence for Theft of Copper | State: surveillance, eyewitness ID, physical items (shirt, tools), and recovery of copper support conviction | Williams: disputes involvement in the Sharyland theft | Held: Evidence legally sufficient to prove theft beyond a reasonable doubt |
| Legal sufficiency of evidence for Unauthorized Use of Motor Vehicle | State: video shows removal and operation of meter-reader truck; truck recovered near Brown’s house; Williams aided or participated | Williams: denies responsibility for driving/using the truck | Held: Evidence legally sufficient to prove unauthorized use beyond a reasonable doubt |
Key Cases Cited
- Chambers v. State, 711 S.W.2d 240 (Tex. Crim. App.) (appellate consideration of hearsay weighed by factfinder)
- Clewis v. State, 922 S.W.2d 126 (Tex. Crim. App.) (standard for legal-sufficiency review)
- Dewberry v. State, 4 S.W.3d 735 (Tex. Crim. App.) (appellate courts may not reweigh evidence as a thirteenth juror)
- Jackson v. Virginia, 433 U.S. 307 (U.S. 1979) (Jackson standard: evidence sufficient if any rational trier of fact could find guilt beyond a reasonable doubt)
- Threadgill v. State, 146 S.W.3d 654 (Tex. Crim. App.) (applying Jackson standard)
- Watson v. State, 204 S.W.3d 404 (Tex. Crim. App.) (courts must consider all evidence the jury relied on, including unobjected hearsay)
- Poindexter v. State, 153 S.W.3d 402 (Tex. Crim. App.) (confirming appellate consideration of unobjected-to hearsay)
- Fernandez v. State, 805 S.W.2d 451 (Tex. Crim. App.) (background on admissibility and weight of hearsay)
- Johnson v. State, 23 S.W.3d 1 (Tex. Crim. App.) (discussion of sufficiency review principles)