Shirley Williams v. United States, 90 A.3d 1124

On Sept. 29, 2011, Shirley Williams (petitioner) got into a physical altercation at the Bragg home while picking up her children; testimony conflicted about who started the fight.
Williams (small stature) testified Jennifer Bragg (larger) grabbed and attacked her, threw objects as Williams retreated, and the locked front door blocked escape.
In the kitchen Williams picked up a knife, banged it on a door, yelled a potentially ambiguous remark, and surrendered the knife to Adrian Donald when he grabbed her hand; there was no evidence she advanced or menaced the Braggs with the knife.
The government did not call the complaining witness (Jennifer Bragg); prosecution relied on Gregory Bragg, Adrian Donald, and a responding officer.
At bench trial the court found the truth lay "somewhere in between," concluded Williams brandished the knife and was not justified in having it, but did not make explicit credibility findings on who initiated the attack.
On appeal the D.C. Court of Appeals held the evidence was insufficient for the government to disprove self-defense beyond a reasonable doubt and reversed with instructions to enter acquittal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence sufficed to disprove Williams's self-defense claim beyond a reasonable doubt for attempted unlawful possession of a prohibited weapon	Government: Williams picked up and brandished a knife and her words showed threatening intent; she was not justified	Williams: She acted to defend herself from a larger attacker who hurled objects and blocked escape; display of the knife was defensive and she relinquished it without menacing conduct	Reversed — evidence insufficient to disprove self-defense beyond a reasonable doubt; conviction vacated and acquittal ordered

Potter v. United States, 534 A.2d 943 (explaining self-defense can negate intent element for weapon possession)
Gay v. United States, 12 A.3d 643 (excessive-force analysis and contexts where responsive force defeats self-defense)
Douglas v. United States, 859 A.2d 641 (distinguishing cases where trial court discredits self-defense testimony)
Peery v. United States, 849 A.2d 999 (reversal and acquittal when evidence insufficient to sustain conviction)
Rivas v. United States, 783 A.2d 125 (explaining reasonable-doubt sufficiency review and that ambiguous facts can require acquittal)
Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence review)