Williams v. State
959 N.E.2d 357
Ind. Ct. App.2011Background
- Police respond to a disturbance at Williams's home; six people present, officers take statements.
- Williams yells, flails, and ignores orders to sit; she obstructs the investigation.
- Williams's husband is arrested for battery; Williams becomes more belligerent.
- She attempts to go to the kitchen; officers fear she may retrieve a weapon.
- Officers handcuff Williams for safety after she resists; she is arrested for resisting law enforcement.
- Bench trial convict Williams; on appeal she challenges the sufficiency of evidence and legality of the stop.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the evidence sufficient to convict Williams? | Williams | Williams | Conviction affirmed |
| Were officers lawfully engaged in their duties when handcuffing Williams? | Williams | Williams | Officers lawful; reliance on Briggs absent; affirmed |
Key Cases Cited
- Briggs v. State, 873 N.E.2d 129 (Ind.Ct.App.2007) (consent/standards for lawful engagement distinction)
- Stewart v. State, 945 N.E.2d 1277 (Ind.Ct.App.2011) (reweighing not allowed; sufficiency standard)
- Wright v. State, 828 N.E.2d 904 (Ind.2005) (sufficiency standard of review)