Summary
The Supreme Court of Florida reviewed Malik Jimer Williams’s convictions and sentences arising from the shooting death of John Edward Brown, III. The court held that the trial court properly denied Williams’s motion for judgment of acquittal because the evidence presented a credibility issue regarding his self-defense theory. The court affirmed the convictions, quashed the decision below as to the sentences, and remanded for resentencing under applicable Florida law.
Topics
Practice areas
Questions Presented
- Whether the trial court erred in denying Williams's motion for judgment of acquittal where he presented a prima facie case of self-defense and the evidence was allegedly insufficient for the State to rebut self-defense beyond a reasonable doubt.
- Whether Williams was entitled to resentencing under chapter 2014-220, Laws of Florida, and the Supreme Court of Florida's decision in Williams v. State, 186 So. 3d 989.
Holdings
- The trial court properly denied the motion for judgment of acquittal because Williams presented a prima facie case of self-defense, but the State presented evidence from which a reasonable jury could reject his explanation and find that the altercation arose from an attempted robbery. The equivocal evidence and conflicting testimony created a credibility determination for the jury rather than a legal insufficiency requiring acquittal.
- Williams was entitled to resentencing under chapter 2014-220, Laws of Florida, and Williams v. State, 186 So. 3d 989, as conceded by the State.
Key quotations
“If, after viewing the evidence in the light most favorable to the State, a rational trier of fact could find the existence of the elements of the crime beyond a reasonable doubt, sufficient evidence exists to sustain a conviction.” (at 5)
“A trial court must grant a judgment of acquittal when the State’s case is legally insufficient to rebut a defendant’s prima facie case establishing self-defense.” (at 5)
“However, a judgment of acquittal should be denied where a jury would reasonably reject the defendant’s explanation of self-defense.” (at 5)
Factual background
On February 15, 2013, Williams and his cousin encountered Reginald Johnson and John Edward Brown, III, while riding bicycles in Tampa. Williams testified that Johnson and Brown followed or maneuvered toward him and that Brown had a gun; after the group dismounted and an altercation began, Williams obtained the gun and shot Brown twice and Johnson once. Evidence at the scene, including unfired ammunition, other physical evidence, eyewitness testimony, and surveillance video, was equivocal as to how the altercation began and whether it resulted from an attempted robbery or self-defense.
Procedural history
A jury found Williams guilty of first-degree premeditated murder and guilty of theft as a lesser included offense of robbery; the trial court imposed sentences including a sentence for first-degree murder and a sentence for attempted first-degree murder. The Second District initially issued a per curiam affirmance, withdrew it, and substituted a written opinion affirming the convictions and sentences. The Supreme Court of Florida accepted review, addressed the judgment-of-acquittal issue, and remanded for resentencing based on the State's concession.
Remand instructions
The Second District Court of Appeal's decision was affirmed in part and quashed in part. The case was remanded with instructions to remand to the trial court for resentencing in accordance with Williams v. State, 186 So. 3d 989, and Thomas v. State, 177 So. 3d 1275, and chapter 2014-220, Laws of Florida.