State v. James Caleb Williams

Syllabus

James Caleb Williams was indicted for the attempted murder of Ashley R., the attempted murder of Malik Myers, and one count of possession of a weapon during the commission of a violent crime. A jury convicted Williams of the attempted murder of Ashley R. and the possession charge. The court of appeals reversed Williams' convictions in a 2-1 opinion. State v. Williams, 435 S.C. 288, 867 S.E.2d 430 (Ct. App. 2021). The majority concluded the trial court erred in not granting Williams' directed verdict motion as to the attempted murder of Ashley R. because the doctrine of transferred intent, which the State relied on to prove Williams' intent to kill Ashley R., does not apply to specific intent crimes, such as attempted murder. The dissent disagreed and found the issue unpreserved. We granted the State's petition for a writ of certiorari to address whether transferred intent applies to specific intent crimes. After further deliberation, we find this issue was not preserved at trial. We therefore reverse the court of appeals' majority opinion.