WILLIAMS v. STATE (2025)

MEMORANDUM DECISION

Case Summary

[1] Following a jury trial, Joseph Williams was convicted of murder, a felony. Williams appeals and claims that the State failed to rebut Williams’ claim of self-defense and failed to present evidence of his intent to kill. We disagree and, accordingly, affirm.

Issues

[2] Williams presents two issues, which we reorder and restate as:

I.  Whether the State presented sufficient evidence to establish that Williams knowingly killed the victim.

II. Whether the State presented sufficient evidence to rebut Williams’ claim of self-defense.

Facts

[3] On November 4, 2023, Williams and Martinez Lambert were drinking alcohol together. At some point, Lambert drove Williams to the Beacon Heights apartment complex in South Bend, where Williams lived with his girlfriend, Kourtney Wheaton. When Williams and Lambert arrived at the apartment complex, they got out of Lambert's car. Lambert called his cousin, Terrance Harris. While Lambert spoke with Harris, Williams asked Lambert to drive him to a liquor store. Lambert told Williams to wait until Lambert's conversation with Harris was finished. The two began to argue over the matter, and, at some point during the argument, Williams went inside the apartment and grabbed a knife. When Williams told his girlfriend to go get Williams’ pistol, Lambert laughed and claimed that Williams’ pistol had “no clip and no bullets.” Tr. Vol. II p. 38. Williams then pulled out the knife and stabbed Lambert once in the chest.

[4] Taira Kennedy, a resident at the apartment complex, was in her grandmother's car with her nephew when the stabbing occurred. She saw two men arguing after one of them, wearing a white shirt, had come out of an apartment. When the argument got loud, Kennedy began to video record it with her phone. The man in the white shirt went back into the apartment, came back outside wearing a black shirt, and stabbed the other man. The man in the black shirt then went back into the apartment “like it was nothing.” Id. at 19-20. After the stabbing, Kennedy called 911. The video Kennedy took depicts Lambert on all fours on the sidewalk after the stabbing, while Williams walks back to his apartment. State's Ex. 2.

[5] Law enforcement responded to the 911 call and found Lambert lying on the sidewalk in a pool of blood. Harris, who was still on the phone with Lambert at the time of the stabbing, heard Williams and Lambert arguing, and heard a scuffle. When Lambert did not respond after the scuffle, Harris drove to the apartment complex and saw Lambert lying on the ground, but the police prevented him from approaching Lambert. The officers noted a large stab wound on Lambert's upper-left chest. They also found a cell phone on the ground next to Lambert. The police located no weapon on or near Lambert's body. Lambert was transported to the hospital via ambulance and was pronounced dead. His cause of death was determined to be the stab wound.

[6] About one hour after the stabbing, South Bend Police Department Detective Phillip Simms saw a person matching Williams’ description six-to-eight blocks from the apartment complex. Williams saw Detective Simm's vehicle and fled. Detective Simms briefly chased Williams and told Williams to stop. Williams soon complied and lay down on the ground. After the police gave the Miranda warnings, Williams told the police that a “dude” had “ran up on” him and threatened him with a gun. State's Ex. 5 at 2:30. Williams claimed this incident occurred at a nearby library. Williams denied knowing where Beacon Heights was and claimed that he was homeless. When Williams was questioned at the police station, he claimed that nothing had happened at the library, and he denied knowing Kourtney Wheaton. The police obtained a search warrant for the apartment Williams shared with Wheaton. There, they located a steak knife in the sink and an identification card with Williams’ name. A search of a car found at the crime scene revealed documents with Lambert's name.

[7] On November 6, 2023, the State charged Williams with murder. A jury trial was held on May 13-15, 2024. Williams testified on his own behalf and claimed that Lambert had overstayed his welcome at Williams’ apartment and been told to leave. Williams claimed that, after Lambert left, he heard someone kicking at his door. When Williams went to investigate, he saw Lambert outside talking on his phone. Williams testified that Lambert had his hand in the pocket of a green hooded sweatshirt. Williams claimed that he knew Lambert owned a gun, so Williams grabbed a steak knife to scare Lambert and get him to back up. Williams claimed that he did not mean to stab Lambert in the chest and had just made a stabbing motion. Williams stated that, after he made the stabbing motion, Lambert asked, “Did you poke me?” Id. at 138. Williams responded, “yeah,” and then asked Lambert to “just go.” Id. Williams claimed that he did not know that Lambert was injured. Williams testified that he left the apartment because he and Wheaton were afraid Lambert would return. Wheaton also testified and stated that Lambert had been belligerent and angry when inside the apartment, but she did not witness the stabbing.

[8] The jury rejected Williams’ claim of self-defense and found him guilty as charged. The trial court later sentenced Williams to the advisory term of fifty-five years of incarceration. Williams now appeals.

Discussion and Decision

I. The State presented sufficient evidence of a knowing killing.

[9] We first address Williams’ claim that the State failed to present evidence of his intent to kill. To convict Williams of murder, the State was required to prove beyond a reasonable doubt that he knowingly or intentionally killed Lambert. See Ind. Code § 35-42-1-1(1). Thus, the State need only to have proved that Williams knowingly killed Lambert, not that he necessarily intended to do so. “A person engages in conduct “intentionally” if, when he engages in the conduct, it is his conscious objective to do so.” Ind. Code § 35-41-2-2(a). “A person engages in conduct “knowingly” if, when he engages in the conduct, he is aware of a high probability that he is doing so.” Id. § 2(b).

[10] The evidence favorable to the jury's verdict shows that Williams stabbed Lambert in the chest with a knife. A knowing killing may be inferred from the use of a deadly weapon in a way likely to cause death. Leonard v. State, 73 N.E.3d 155, 161 (Ind. 2017) (citing Young v. State, 761 N.E.2d 387, 389 (Ind. 2002)). Thus, the jury could reasonably infer that Williams knowingly killed Lambert when he used a kitchen knife to stab Lambert in the chest. See Eichelberger v. State, 773 N.E.2d 264, 266 (Ind. 2002) (sufficient evidence to infer knowing killing where defendant stabbed victim in the chest with a knife).

II. The State rebutted Williams’ claim of self-defense.

[11] Williams's main argument is that the State failed to rebut his claim of self-defense. “Self-defense is a legal justification for an otherwise criminal act.” Stewart v. State, 167 N.E.3d 367, 376 (Ind. Ct. App. 2021) (citing Gammons v. State, 148 N.E.3d 301 (Ind. 2020)), trans. denied. The statute governing the defense of self-defense provides that an individual has the right to use “reasonable force against any other person to protect the person or a third person from what the person reasonably believes to be the imminent use of unlawful force.” Ind. Code § 35-41-3-2(c). A person is justified in using deadly force, and does not have a duty to retreat, only if the person reasonably believes such force is necessary to prevent serious bodily injury to himself or a third person, or to prevent the commission of a forcible felony. I.C. §§ 35-41-3-2(c)(1), -(2).

[12] Thus, to prevail in presenting a self-defense claim, the defendant must show that: (1) he was in a place where he had a right to be; (2) he did not provoke, instigate, or participate willingly in the violence; and (3) if the defendant used deadly force, he had a reasonable fear of death or great bodily harm. Stewart, 167 N.E.3d at 376 (citing Wilson v. State, 770 N.E.2d 799, 800 (Ind. 2002)). If a defendant raises a self-defense claim that finds support in the evidence, the State has the burden of negating at least one of the necessary elements. Id. (citing Hughes v. State, 153 N.E.3d 354, 361 (Ind. Ct. App. 2020)). The State may meet this burden by rebutting the defense directly—by affirmatively showing the defendant did not act in self-defense—or by simply relying on the sufficiency of the evidence in its case-in-chief. Id. (citing Miller v. State, 720 N.E.2d 696, 700 (Ind. 1999)).

[13] Whether the State has met its burden of disproving a defendant's claim of self-defense is a question of fact for the fact-finder. Id. at 376. Our review of the fact-finder's conclusion is entitled to considerable deference. Taylor v. State, 710 N.E.2d 921, 924 (Ind. 1999). This is because the standard of review for a challenge to the sufficiency of the evidence to rebut a claim of self-defense is the same as the standard for any sufficiency of the evidence claim. Stewart, 167 N.E.3d at 376. When analyzing a claim of insufficient evidence to rebut a claim of self-defense, we may consider only the probative evidence and reasonable inferences supporting the judgment. Id. It is the jury's role, not that of appellate courts, to assess witness credibility and weigh the evidence to determine whether it is sufficient to support a conviction. Id.

[14] Here, the facts most favorable to the jury's verdict show that Williams and Lambert got into an argument while Lambert was on the phone with his cousin. Williams told his girlfriend to go get his pistol, at which point Lambert claimed that Williams’ gun did not have ammunition. At some point, Williams went into the apartment he shared with his girlfriend, got a knife, and came back outside. Williams then stabbed Lambert one time and walked back into his apartment. Williams then fled the scene and, when he was apprehended, made wild claims about someone trying to kill him at the library. Then, at the police station, he claimed not to remember his earlier statements and also claimed that he did not know where the Beacon Heights apartments complex was; he also claimed that he did not know Wheaton, his girlfriend. At trial, Williams changed his story and claimed that Lambert had threatened him and that Williams did not intend to stab Lambert. From this, the jury could reasonably conclude that the State rebutted Williams’ claim of self-defense.

[15] Williams argues that he presented evidence establishing all the elements of self-defense: he was in a place he had a right to be; he did not provoke, instigate, or participate willingly in the violence; and he had a reasonable fear of death or great bodily harm. Stewart, 167 N.E.3d at 376. Williams’ argument, however, is based on evidence that does not favor the jury's verdict, which we may not consider on appeal. Id. Although Williams presented evidence that may have supported a claim of self-defense, the jury was under no obligation to credit the testimony and evidence favoring Williams’ self-defense claim. See id.

[16] The jury could also reasonably conclude that Williams displayed consciousness of guilt by fleeing the scene and lying about the incident to the police when he was apprehended. This behavior suggests that Williams was aware that his actions were criminal and was attempting to avoid arrest, and it undercuts his claims that he was justified in stabbing Lambert. See Myers v. State, 27 N.E.3d 1069, 1070 (Ind. 2015) (holding that evidence of flight may be considered as evidence of consciousness of guilt); Orozco v. State, 146 N.E.3d 1038, 1041-42 (Ind. Ct. App. 2020) (holding that evidence of defendant's flight and disposal of the murder weapon was evidence from which the fact-finder could reasonably conclude that “the murder was not committed in self-defense.”), trans. denied. In short, the State presented evidence sufficient to rebut Williams’ claim of self-defense.

Conclusion

[17] The State presented evidence sufficient to prove Williams’ intent to kill and to rebut Williams’ claim of self-defense. Williams’ arguments to the contrary are simply a request that we consider evidence that does not favor the jury's verdict, judge the credibility of the witnesses, and come to a conclusion different from that reached by the jury. This is not our role as an appellate court. Accordingly, we affirm the trial court's judgment.

[18] Affirmed.

Tavitas, Judge.

May, J., and DeBoer, J., concur.