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Williams v. State
Citations: 17 Ark. App. 53; 702 S.W.2d 825; 1986 Ark. App. LEXIS 2007Docket: CA CR 85-128
Court: Court of Appeals of Arkansas; February 5, 1986; Arkansas; State Appellate Court
James Charles Williams was convicted of second degree murder for the stabbing death of his brother, Fred Williams, after an argument during a card game on October 14, 1984. He was sentenced to thirty years in prison. The sole issue on appeal was whether the trial court erred in not instructing the jury on the lesser included offense of manslaughter. The appellate court reversed the conviction and remanded the case. Witness testimony indicated that an argument escalated, with Fred Williams attempting to defend himself with a chair as James Williams brandished a knife. James claimed he did not intend to kill his brother and that the situation escalated rapidly, resulting in him stabbing Fred multiple times. Medical examiner Dr. Lee Beamer confirmed that Fred died from five stab wounds. James requested a manslaughter instruction, which the trial court denied, stating the evidence did not support such a charge. Manslaughter, defined under Arkansas law, involves recklessly causing another's death, characterized by a conscious disregard of a substantial risk. The appellate court found sufficient grounds to warrant the manslaughter instruction based on the evidence presented. Second degree murder is defined as knowingly causing another person's death with extreme indifference to human life or with intent to cause serious injury, as per Ark. Stat. Ann. 41-1503(l)(b) and (c) Repl. 1977. In the current case, the jury was instructed based on this definition. The Arkansas Supreme Court in Robinson v. State emphasized the importance of allowing jury instructions on lesser included offenses, regardless of a trial judge's belief in the strength of evidence for a more serious charge. A refusal to instruct on a lesser included offense, when there is sufficient evidence for a reasonable basis for such a finding, constitutes reversible error (Glover v. State). If no evidence contradicts an element of the greater offense, the jury must decide only between the charged offense and acquittal (Fisk v. State). Conversely, if there is even slight evidence disputing an element of the greater offense, failing to provide an instruction on the lesser offense is erroneous (Brewer v. State). In this case, evidence suggested the appellant might have recklessly caused his brother's death, allowing for a potential jury finding of lacking intent for the more serious charge. The jury's role is to evaluate conflicting evidence. Prior cases like Savannah v. State and Bongfeldt v. State illustrate that a jury could find a defendant guilty of a lesser offense based on their testimony. Ultimately, the court found it prejudicial error to deny the instruction on manslaughter, leading to a reversal and remand for a new trial, with dissent from Cooper and Glaze, JJ.