State v. Williams, 187 Conn. App. 333

Background

On Feb. 26, 2013, Williams, Jones, and Pryce went to an East Hartford apartment complex after Jones had a dispute with Jouleigh Clemente; at least two men were seen in dark clothing and ski masks carrying metal bats attempting to force entry into unit 69.
Residents reported banging on a door and a bat stuck in the doorway; some occupants pushed the bat out and locked the door; a 911 call was placed describing masked males with a bat.
Clemente fled unit 69 and fought Jones outside; Williams stood nearby holding a bat and wore a ski mask and was carrying a pocketknife; he did not intervene in the fight between Jones and Clemente.
During a separate altercation with Jonathan Lopez (Clemente’s stepfather), Williams pulled a knife and repeatedly stabbed Lopez; Lopez later died. Williams, Jones, and Pryce were arrested in a vehicle shortly after.
Williams was tried and convicted of manslaughter (reduced from murder) and attempt to commit home invasion under Conn. Gen. Stat. §§ 53a-49 and 53a-100aa(a)(1); he appealed the sufficiency of the evidence supporting the attempt-to-commit-home-invasion conviction.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that Williams took a substantial step to unlawfully enter unit 69	Evidence of masked men with bats, banging on door, and Williams later holding a bat supports an inference he attempted to enter unit 69	Williams was not proven to have personally attempted entry; at trial prosecutor framed him as backup	The court held there was sufficient evidence Williams took a substantial step toward unlawfully entering unit 69
Sufficiency of evidence that Williams had specific intent to commit felony assault on Clemente inside unit 69	State argued Williams was armed (knife), dressed for criminal purpose, and could be inferred to intend serious assault on Clemente	Williams argued state failed to show he knew or targeted Clemente; prosecutor’s trial theory portrayed him as backup for Jones, not the principal assailant	The court held evidence was insufficient to prove Williams specifically intended to commit felony assault on Clemente; conviction on that count reversed
Reliance on co-defendants’ intent to supply Williams’s intent	State argued principal liability allows inference from group conduct that Williams shared the criminal purpose	Williams argued he was charged as a principal, not an accessory, so another’s intent cannot substitute for his own	Court rejected inferring Williams’s intent from a codefendant’s intent because Williams was charged only as a principal
Permissibility of inferring intent from possession/use of weapon later in event	State argued use of knife on Lopez permitted inference he brought it intending to use it on Clemente	Williams noted knife was used only after a later fight with Lopez; no evidence the knife was removed during the attempted entry or directed at Clemente	Court found no evidence knife was displayed or intended for use on Clemente during the attempt; such inference would be speculative

Key Cases Cited

State v. Gemmell, 151 Conn. App. 590 (discussing standard for sufficiency review and inferences from evidence)
State v. Carter, 317 Conn. 845 (state may not change theory on appeal; when intent targets a specific person, evidence must show defendant’s specific intent toward that person)
State v. Josephs, 328 Conn. 21 (factfinder may draw reasonable inferences but not rest convictions on conjecture)
State v. Washington, 186 Conn. App. 176 (substantial-step analysis for attempt requires conduct strongly corroborative of criminal purpose)
State v. Davis, 163 Conn. App. 458 (review limits when jury was not instructed on accessorial liability)
State v. Faulkner, 48 Conn. App. 275 (conviction cannot rest on accessorial theory if jury was instructed only on principal liability)
State v. Channer, 28 Conn. App. 161 (same point regarding limitation to principal liability when no accessorial instruction given)