People v. Williams, 77 N.E.3d 153

Defendant Kimberly J. Williams was tried by the court on two counts of aggravated battery (use of a bat) after an altercation with Theresa Washington; a directed finding was granted on a separate battery count.
The parties met via an internet site; they drank together at a restaurant and at defendant’s home; an altercation occurred that left Washington with a broken arm and other injuries and defendant with scratches and contusions.
Washington’s version: defendant struck her repeatedly with a baseball bat, including after Washington had fallen and was calling for help; Washington fled to a neighbor for help.
Defendant’s version: Washington made unwanted sexual advances, pulled defendant by the hair, and attacked; defendant retrieved a bat and struck Washington in fear of a sexual assault, including additional blows when Washington appeared to recover and turn toward her on the porch.
The trial court found defendant used deadly force and rejected self-defense as unreasonable, concluding that even if it credited defendant’s account, additional blows after Washington fell were unjustified; defendant was convicted on both aggravated-battery counts and sentenced to concurrent 54-month terms.
On appeal the court affirmed the convictions as to self-defense and fairness of trial but vacated one aggravated-battery conviction under the one-act, one-crime rule because the indictment and trial did not apportion separate physical acts for the two counts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to disprove self-defense	State: defendant’s belief that deadly force was necessary was unreasonable; evidence showed excessive force after attack ended	Williams: she reasonably feared imminent sexual assault and used bat in self-defense	Affirmed — appellate court defers to trial court credibility findings; evidence disproved self-defense beyond a reasonable doubt
Right to fair trial based on court’s recollection of porch events	State: no plain error; defendant forfeited the issue	Williams: court misrecollected critical testimony (that Washington turned as if to attack), depriving her of fair trial	Forfeited; no plain error — court’s recollection supported by record and any omission was alternative basis, not deprivation of due process
One-act, one-crime rule (multiple convictions for same physical act)	State: convictions premised on separate acts? (did not apportion)	Williams: both counts arise from same physical act(s) of striking with bat and require vacatur of one conviction	Vacated one aggravated-battery conviction — indictment and trial did not apportion separate blows or injuries, so multiple convictions not permitted

People v. Collins, 106 Ill. 2d 237 (1985) (standard for reviewing sufficiency of the evidence)
People v. Lee, 213 Ill. 2d 218 (2004) (elements of self-defense and reasonableness requirement)
People v. Jeffries, 164 Ill. 2d 104 (1995) (self-defense framework)
People v. Crespo, 203 Ill. 2d 335 (2003) (State must apportion conduct among counts to support multiple convictions for related acts)
People v. Miller, 238 Ill. 2d 161 (2010) (one-act, one-crime two-step analysis)
People v. Artis, 232 Ill. 2d 156 (2009) (standard of review for one-act, one-crime questions)
People v. Almond, 2015 IL 113817 (2015) (permitting multiple convictions only where separate interrelated acts are shown)
People v. Mitchell, 152 Ill. 2d 274 (1992) (court’s failure to recall/consider central defense testimony can deny fair trial)
People v. Piatkowski, 225 Ill. 2d 551 (2007) (plain-error doctrine and its two prongs)