State v. Williams, 5835

Background

Night of May 2, 2015: gunfire in Club Cream parking lot. Three people were shot—Ashley R. (15) in the thigh, Malik Myers in the leg, and Qawiyy McFadden in the ear.
Police recovered six .40-caliber cartridge cases and a Springfield XD .40 at the scene; Myers admitted firing a .38 revolver that night.
Williams was indicted for two counts of attempted murder (one for shooting at Myers, one for allegedly attempting to kill Ashley by firing at Myers) and possession of a weapon during a violent crime.
Ballistics: all six cartridge cases were linked to the recovered .40 Springfield, but the bullet removed from Ashley was inconclusively matched to that gun.
At trial Williams testified he fired into the back of his own car to scare Myers and discarded his gun; the jury acquitted him of attempted murder of Myers but convicted him of attempted murder of Ashley and the weapons charge.
The Court of Appeals reversed Williams’s attempted-murder conviction (and the dependent weapons conviction), holding transferred intent was inapplicable to the statutory attempted-murder charge requiring specific intent to kill.

Issues

Issue	State's Argument	Williams' Argument	Held
Whether the trial court erred in denying a directed verdict on attempted murder of Ashley R.	Proceeding under transferred intent: Williams fired at Myers with malice; the bullet that struck Ashley came from his firing, so intent transfers.	No direct or substantial circumstantial evidence Williams specifically intended to kill Ashley; transferred intent cannot supply required specific intent.	Court: Attempted murder requires specific intent; transferred intent is inapplicable here; reversed attempted-murder conviction.
Whether ballistic evidence sufficiently tied Ashley’s wound to Williams’s gun	Cartridge cases at scene matched Williams’s .40; rifling similarities gave a jury question.	SLED comparison was inconclusive as to the recovered bullet; insufficient to prove Williams fired the fatal round.	Ballistics were inconclusive as to the recovered bullet; insufficient alone to establish required specific intent.
Whether jury’s acquittal for Myers is reconcilable with guilty verdict for Ashley under transferred-intent theory	Transferred intent permits establishing specific intent to kill another by proof of intent to kill intended target.	Inconsistent verdicts demonstrate transferred intent cannot be used to convict for Ashley absent specific intent toward her.	Court found it could not reconcile acquittal on Myers with conviction for Ashley under transferred-intent theory and relied on specific-intent requirement to reverse.
Whether possession-of-weapon conviction stands if attempted-murder conviction is reversed	Weapon conviction supports enhanced sentence tied to violent crime conviction.	Weapon enhancement requires a valid underlying conviction for a violent crime.	Court reversed and remanded the weapon conviction because reconviction on the violent crime is required before weapon enhancement.

Key Cases Cited

State v. King, 422 S.C. 47 (S.C. 2017) (attempted murder requires specific intent to kill)
State v. Gerald Williams, 427 S.C. 148 (S.C. 2019) (discussed transferred intent and left its applicability to attempted murder unresolved)
State v. Smith, 430 S.C. 226 (S.C. 2020) (reversed on other instructional grounds and declined to decide transferred-intent applicability to attempted murder)
State v. Sutton, 340 S.C. 393 (S.C. 2000) (definition of specific intent relied on in later cases)
State v. Brannon, 388 S.C. 498 (S.C. 2010) (directed verdict standard: accused entitled when State fails to present evidence on a material element)