People v. Williams
2017 IL App (3d) 140841
| Ill. App. Ct. | 2017Background
- Defendant Kimberly J. Williams was indicted for two counts of aggravated battery (use of deadly weapon; great bodily harm) and one count of battery for striking Theresa Washington with a baseball bat after a meeting arranged online; bench trial followed defendant’s notice of self-defense.
- Facts disputed: Washington testified defendant unexpectedly attacked her with a bat after a fight, causing a broken arm and other injuries; defendant testified Washington initiated a sexual/physical assault late at night (pulling hair, pushing, breaking a table) and she used the bat to repel an ongoing attack.
- Trial court found both accounts contained similar core facts but resolved credibility in favor of Washington, concluding defendant used deadly force and her belief that deadly force was necessary was unreasonable.
- Court emphasized that after Washington fell/slid down the stairs and was calling for help, any threat had ended and further strikes with the bat were unjustified.
- Defendant was convicted on both aggravated-battery counts (battery count dismissed at trial) and sentenced to concurrent 54-month terms; she appealed challenging sufficiency (self-defense), denial of a fair trial, and one-act/one-crime multiplicity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency: Was self-defense disproved beyond a reasonable doubt? | State: Court could reject self-defense because defendant’s belief that deadly force was necessary was objectively unreasonable. | Williams: Evidence supports her subjective/reasonable belief of imminent sexual assault and need for deadly force. | Affirmed: Court credited State; defendant’s belief unreasonable and deadly force unjustified. |
| Right to fair trial: Did the trial judge deprive defendant by misrecalling/omitting crucial defense testimony? | State: No forfeited error; judge’s recollection was supported and omission reflected implicit rejection of that testimony. | Williams: Judge relied on an inaccurate recollection (porch events), depriving her of due process. | Forfeited; no plain error: Court found no error in judge’s recollection or consideration, and alternate findings independently support verdict. |
| Plain-error standard applicability | State: Issue forfeited; plain-error not triggered because no clear error affecting fairness. | Williams: Even if forfeited, plain error applies because judge failed to consider crux of defense. | Affirmed: No plain error; judge’s ruling supported by record and alternative basis not erroneous. |
| One-act, one-crime (multiplicity) | State: Two convictions reflect separate harms (insulting contact vs. great bodily harm). | Williams: Both counts stem from the same act(s) of striking with a bat; no notice State would treat blows separately. | Vacated one conviction (count II): Counts not apportioned; under Crespo line multiple convictions for the same physical act not permitted. |
Key Cases Cited
- People v. Lee, 213 Ill.2d 218 (Ill. 2004) (elements of self-defense)
- People v. Jeffries, 164 Ill.2d 104 (Ill. 1994) (self-defense burden and reasonableness)
- People v. Crespo, 203 Ill.2d 335 (Ill. 2003) (State must apportion acts to support multiple convictions under one-act, one-crime)
- People v. Miller, 238 Ill.2d 161 (Ill. 2010) (one-act, one-crime two-step framework)
- People v. Artis, 232 Ill.2d 156 (Ill. 2009) (standard of review for one-act, one-crime)
- People v. Almond, 2015 IL 113817 (Ill. 2015) (multiple convictions allowed for interrelated acts; single-act bar explained)
- People v. Mitchell, 152 Ill.2d 274 (Ill. 1992) (trial court’s failure to remember/consider critical defense testimony can implicate due process)
- People v. Piatkowski, 225 Ill.2d 551 (Ill. 2007) (plain-error doctrine two-prong test)