Christopher A. Williams, a fourteen-year-old, was indicted for first-degree murder, felony murder, and attempted aggravated robbery. His first trial ended in a mistrial, while the second trial resulted in a hung jury on the murder charges but a conviction for attempted aggravated robbery. He was sentenced to six years in a county workhouse and a $1,000 fine. Williams appealed, challenging the sufficiency of the evidence, but the appellate court affirmed the trial court's judgment.
The incident occurred on August 19, 1995, when Michael Byrd discovered the victim, Jerry McNeal, lying motionless with visible blood and called the police. Officer Cham Payne confirmed the victim had been shot multiple times. Eyewitness testimony indicated gunshots were heard shortly before the victim was found. Officer Edward Cash, investigating the murder, received a tip implicating Williams and subsequently interviewed him and his mother, who both cooperated. During the interview, Williams admitted to shooting the victim and described the firearm used as a .25 semi-automatic he obtained from a person he referred to as "Black." He provided a physical description of "Black," indicating he was involved in the incident.
The defendant described the attire of "Black" during the shooting as knee-length shorts, a dark button-up shirt, black tennis shoes, and potentially a gold wristwatch. The incident occurred on a path known as the "cut" leading from Kingsgate Apartments to the church's rear parking lot. The defendant recounted that he and "Black" approached a male victim after leaving a gas station, at which point "Black" suggested robbing him. The defendant was handed a .25 semi-automatic pistol and called the victim over. When the victim attempted to deflect the gun, the defendant shot him in the leg and fired three additional shots as the victim fled toward the church. After the shooting, the victim collapsed, and the defendant and "Black" walked back through the "cut" to the apartments.
The pistol used in the shooting was hidden in bushes by "Black," who referred to it as a "stash spot." However, when the defendant and his mother later returned to search for the gun, it was no longer there. The defendant claimed he did not know what happened to it and stated that "Black" did not fire a weapon during the robbery attempt. Additionally, no valuables were obtained from the victim.
The defendant expressed remorse, believing he had not killed the victim. Following the interview with Officer Cash, the defendant and his mother were asked to initial and sign each page of the statement, which they did on August 22, 1995. Officer Cash confirmed that no gun was found at the described hiding spot and noted that despite the defendant's age of fourteen, he was not taken to juvenile court. Officer Cash denied any coercion during the interrogation and stated that the defendant was not handcuffed or placed in a marked patrol car. He acknowledged the absence of recording methods during the interviews and that Sergeant Nichols transcribed the statement verbatim.
Officer Cash acknowledged an error in his prior testimony regarding the timeline of the police search for the murder weapon, clarifying that the search occurred after the defendant's statement, which included details about the search. He also noted that he had considered five other suspects but only interviewed one. Cash admitted that the defendant did not provide any new information during the interview, other than the identity of the shooter, and confirmed that the defendant’s mother was present during the entire interrogation. He stated that the defendant was allowed to eat during questioning.
Dr. Wendy Gunther, a forensic pathologist, testified that the victim died from two lethal gunshot wounds to the back, and a leg wound was deemed minor. Defense witness Gloria Williams claimed that she and her husband, originally from Jamaica, lived at Kingsgate Apartments during the arrest. She recounted that officers handcuffed the defendant and placed him in an unmarked car without her requesting an attorney, asserting that he agreed to everything asked. Williams signed a written statement without reading it, admitting that she learned to always read such documents in the future. She maintained her son promised he did not shoot the victim and thought he was home watching a boxing match during the incident.
The defendant, who had reading difficulties and was sixteen at the time, testified that he was home and had requested a pay-per-view boxing match on the night of the shooting, which he claimed lasted only eight or nine seconds. He denied shooting the victim and stated he went to a place called Honeycomb afterward. He acknowledged knowing the other suspects but denied knowing a person referred to as "Black." He recounted that when police arrived, he was in the bathroom due to drinking, and after being handcuffed and searched, he was placed in a marked police car. He stated that he believed he was being arrested during the interrogation and admitted to signing a waiver of rights form without reading it, unaware that he could request legal representation.
The defendant claimed he informed law enforcement about the location of a hidden gun, asserting it belonged to another suspect, Brodie Moore, whom he saw earlier that day. Upon arrival at the designated location, the gun was not found. He contested the accuracy of his written statement to the police, stating that he did not understand the phrasing used. The defendant denied shooting the victim and maintained that he provided information to the officers only to protect his family, despite admitting to past drug and alcohol use with Moore. Although he was familiar with the area where the victim's body was found, he claimed he was not present on the shooting day.
On appeal, the defendant argued that the evidence was insufficient to prove he shot and robbed the victim, asserting no credible evidence supported the robbery claim and questioning the reliability of his confession. He invoked Rule 12(c) of the Rules of Juvenile Procedure and Tennessee Code Annotated, section 37-1-127(c), arguing his confession should be inadmissible due to procedural violations during his custody. However, he did not challenge the trial court's pre-trial ruling regarding his confession's admissibility or include the motion to suppress hearing transcript in the appeal record.
Rule 12(c) requires that juveniles be informed of their rights and provided counsel if necessary, and any extrajudicial statements obtained in violation of these rules should not be used against them in juvenile court. However, since the defendant was tried as an adult, this rule did not bar the use of his confession. He further contended that Officer Cash's testimony lacked credibility, arguing that no reasonable jury could find him guilty based on that testimony. The appellate court emphasized that the state is entitled to a favorable view of the evidence, and the jury is responsible for assessing witness credibility and resolving conflicts in the testimony. The sufficiency of evidence is evaluated based on whether a rational jury could find the essential crime elements beyond a reasonable doubt. Robbery is defined as the intentional or knowing theft from another person through violence or fear, with aggravation occurring if a deadly weapon is used or serious bodily injury results.
A criminal attempt occurs when a person, acting with the required culpability, intends to complete an action that would constitute an offense and takes a substantial step toward committing that offense, as defined in Tenn. Code Ann. 39-12-101(a)(3). The mental state of intentional is met when the individual's conscious objective is to engage in the conduct or achieve the result. In contrast, the individual acts knowingly if they are aware that their conduct will likely cause the result.
In this case, the defendant confessed to walking with an accomplice, "Black," who suggested robbing a man. The defendant admitted to taking a gun from "Black," aiming it at the victim, and shooting the victim in the leg when he resisted. The court found that all elements of attempted aggravated robbery were satisfied. The jury, aware of the confession's controversy, resolved the disputes in a manner that favored both the state and the defense, which the appellate court cannot reevaluate. Consequently, the trial court's judgment is affirmed. The opinion notes the passing of Judge Joe B. Jones, who did not participate in this decision.
