William S. Smith v. State of Indiana (mem. dec.)
49A02-1603-CR-656
| Ind. Ct. App. | Dec 7, 2016Background
- Victim Azya Knowles dated William S. Smith; her brother brought her a .22-caliber handgun to Smith’s house on Feb. 10, 2015.
- On Feb. 11, Smith was observed driving a pickup with a damaged windshield and shattered passenger window in Haughville; later he drove to the City-County Building carrying a .380 handgun and claiming people had shot at him.
- Police found Knowles on the passenger floorboard of Smith’s truck; she had three fatal .22-caliber gunshot wounds to the head and later died.
- Investigators recovered two .22-caliber shell casings from inside the truck (fired from the same weapon), but no .22 firearm; Smith’s .380 handgun and a .380 shell casing were found in the truck, plus $30,000 cash and marijuana.
- Smith told officers he didn’t shoot her and claimed others from Haughville shot at them; forensic testing indicated some windshield impacts were consistent with bullets fired from inside the truck.
- Smith was tried (pro se), convicted by a jury of murder, carrying a handgun without a license, and marijuana possession, and he appealed arguing insufficient evidence he was the shooter.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence that Smith murdered Knowles | State: circumstantial evidence and inferences (shell casings, bullets, victim in passenger floorboard, windshield impacts, Smith’s statements and conduct) support conviction | Smith: State failed to prove he had access to or fired a .22; no .22 gun produced; conviction rests on speculation | Affirmed: a reasonable jury could infer Smith shot Knowles beyond a reasonable doubt |
Key Cases Cited
- Wilson v. State, 39 N.E.3d 705 (Ind. Ct. App. 2015) (standard for sufficiency review and use of circumstantial evidence)
- Hughes v. State, 546 N.E.2d 1203 (Ind. 1989) (evidence of attempts to conceal or manufacture exculpatory evidence may show consciousness of guilt)
