Michael Williams v. State of Indiana (mem. dec.)
49A02-1704-CR-842
| Ind. Ct. App. | Dec 15, 2017Background
- On Oct. 31, 2015, Michael Williams drove Kevin Wilkerson to a parked car where Wilkerson confronted and demanded items from Raymond Alvarez; Wilkerson produced a gun, grabbed a backpack, and shot Alvarez, killing him; Williams drove away with Wilkerson after the shooting.
- Two weeks later Williams robbed a Family Dollar by handing a note demanding cash and displaying an object the manager believed was a gun; Williams fled with cash in a vehicle driven by Wilkerson.
- Police pursued the vehicle, which stopped after a flat; during a foot chase officers saw Williams discard an item; a black firearm with ridges was recovered at that spot and later tested as the gun used to kill Alvarez.
- Williams had Family Dollar money and the robbery note on him when arrested; his DNA was found on the firearm’s magazine; he admitted driving during Alvarez’s shooting and admitted the Family Dollar robbery but denied having a weapon during that robbery and denied knowing Wilkerson’s actions.
- Williams was convicted at bench trial of felony murder (for Alvarez’s death) and Level 3 felony robbery (for the Family Dollar), and later pled guilty to habitual offender enhancement; aggregate sentence 87 years.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for felony murder (accomplice liability) | State: Williams aided/abetted robbery—present, driving, participated in escape, backpack found in his car, statement at scene supports participation | Williams: No evidence he participated in or knew of the robbery; statement could have been to Wilkerson; N.B. didn’t see him handle the backpack | Affirmed: Evidence sufficient to infer accomplice liability and sustain felony murder conviction |
| Sufficiency of evidence that Williams was armed during Family Dollar robbery (robbery level) | State: Manager saw ridged black object; Williams discarded item during chase; recovered firearm matched murder weapon; Williams’ DNA on magazine | Williams: Denies he was armed during the robbery; contests sufficiency to show he displayed/used a deadly weapon | Affirmed: Evidence sufficient to show Williams was armed with a deadly weapon, supporting Level 3 robbery conviction |
Key Cases Cited
- Willis v. State, 27 N.E.3d 1065 (Ind. 2015) (standard for appellate review of sufficiency of evidence)
- Wieland v. State, 736 N.E.2d 1198 (Ind. 2000) (felony murder can be based on accomplice liability)
- Wright v. State, 828 N.E.2d 904 (Ind. 2005) (conflicting evidence viewed most favorably to the factfinder)