Keith D. Williams v. State of Indiana (mem. dec.)
32A01-1707-CR-1589
| Ind. Ct. App. | Nov 30, 2017Background
- Defendant Keith D. Williams, with a history of schizophrenia, entered Abacus Staffing to apply for work; receptionist Mellissa Fender answered a phone call while he completed the application.
- Williams believed Fender had called him a "he she" during the phone call, became enraged, hurled a clipboard that struck Fender, made graphic threats (including threats to slit her throat), and warned she would "get what was coming to [her]."
- Fender was alone with Williams in the office and testified she was scared; Williams denied the threats and gave a different version involving a third person.
- Williams was charged with Level 6 felony intimidation (threat to retaliate for a prior lawful act) and Class B misdemeanor battery; he waived a jury, was found guilty but mentally ill, and sentenced.
- On appeal Williams argued evidence was insufficient because the "prior lawful act" (Fender allegedly calling him names on the phone) never occurred and he only reacted to a delusion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State proved the "prior lawful act" element of Level 6 intimidation | The prior lawful act was Fender lawfully answering and speaking on the phone to an applicant; Williams mistakenly believed her words referred to him and threatened retaliation for that lawful act | The specific act Williams allegedly retaliated for (being called a "he she") never occurred, so he cannot be convicted for threats responding to something that didn’t happen; his reaction was to a delusion | Affirmed: the prior lawful act was Fender’s lawful phone conversation; Williams’ misperception did not negate the element and evidence was sufficient |
Key Cases Cited
- Huber v. State, 805 N.E.2d 887 (Ind. Ct. App. 2004) (standard for reviewing sufficiency of the evidence)
- Leggs v. State, 966 N.E.2d 204 (Ind. Ct. App. 2012) (appellate standard that convictions stand unless no reasonable fact‑finder could find guilt beyond a reasonable doubt)
- Loyd v. State, 787 N.E.2d 953 (Ind. Ct. App. 2003) (trial court credibility determinations are for the factfinder)