Collin Alan Williams v. State of Indiana (mem. dec.)
71A04-1704-CR-810
Ind. Ct. App.Oct 16, 2017Background
- At ~2:30 a.m. officers responded to a noise complaint at a vacant rental house; they found the front door and windows locked and left.
- About 90 minutes later officers returned to the same address and found the front door unlocked and a side window open; officers heard movement and breaking glass and two people fled, one jumping through the broken window.
- A partial palm print and fresh blood were recovered from the broken window; copper wiring was scattered in the backyard and wiring in the basement and breaker box appeared recently cut.
- Forensic testing and an agreed stipulation at trial established the palm print and blood matched Collin Williams.
- Williams was charged with and tried for class C felony burglary (breaking and entering with intent to commit a felony) and convicted by a jury; he appealed, arguing insufficient evidence of both ‘‘breaking’’ and intent to commit a felony.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence proved a ‘‘breaking’’ to support burglary | The State: door/widow were locked earlier but later found unlocked/ajar; someone forced entry — presence inside supports inference of breaking | Williams: no direct evidence he exerted force to enter; State proved only he broke and exited, not that he broke and entered | The court held circumstantial evidence (locked then unlocked/ajar, presence inside) was sufficient to infer a breaking |
| Whether there was intent to commit a felony inside (theft) | The State: pre-dawn entry, recently cut wiring, wiring strewn in yard, and flight through broken window support an inference of intent to commit theft | Williams: intent not established; breaking and flight alone insufficient to prove intent | The court held additional facts (time, cut wiring, scattered wire, manner of flight) furnished a reasonable inference of intent to commit theft |
Key Cases Cited
- Drane v. State, 867 N.E.2d 144 (Ind. 2007) (standard for sufficiency of evidence review)
- Davis v. State, 770 N.E.2d 319 (Ind. 2002) (even slight force — e.g., opening an unlocked door — satisfies breaking)
- Freshwater v. State, 853 N.E.2d 941 (Ind. 2006) (breaking and flight are not probative of intent unless tied to corroborative evidence)
- Baker v. State, 968 N.E.2d 227 (Ind. 2012) (time, force, and manner of entry may permit inference of intent to commit theft)