Furl J. Williams, Arthur Terence Bullock, and Marteese Norman v. United States

Summary

The District of Columbia Court of Appeals reviewed the robbery convictions of Furl J. Williams, Arthur Terence Bullock, and Marteese Norman. The court held that the government failed to prove beyond a reasonable doubt that the defendants used violence or put the victim in fear, an essential element of robbery under D.C. Code § 22-2801. The court therefore reversed the robbery convictions.

Holdings

1. The government failed to prove beyond a reasonable doubt that appellants used violence or engaged in conduct that objectively would put a reasonable person in fear of imminent bodily harm. The evidence that three people approached Chau, two said “what, what, what,” and Chau handed over his wallet did not establish the required menacing or threatening conduct.
2. Bullock was also entitled to reversal because the government had to prove every element of robbery beyond a reasonable doubt, and the court held that the evidence failed to prove an essential element of the offense.

Questions Presented

1. Whether the evidence was sufficient to prove the violence-or-putting-in-fear element of robbery beyond a reasonable doubt.
2. Whether the court should reverse all three robbery convictions when the sufficiency challenge was expressly raised on appeal by only Williams and Norman but Bullock had challenged sufficiency in the trial court.

Disposition

reversed