State v. Williams

Citations

• 352 Conn. 104

Syllabus

Convicted of manslaughter in the first degree with a firearm, criminal posses- sion of a firearm, criminal possession of ammunition, and carrying a pistol without a permit, the defendant appealed to this court. The defendant's conviction arose from an incident in which he shot and killed a third-party bystander while shooting at another individual who had shot at the defendant first. With respect to the first degree manslaughter charge, the state alleged that the defendant, under circumstances evincing an extreme indifference to human life, had recklessly engaged in conduct that created a grave risk of death to the victim and had caused the victim's death while he was using a firearm. The defendant claimed, inter alia, that the trial court, which had instructed the jury on the defense of self-defense with respect to the charge of murder, of which the defendant was found not guilty, had improperly declined the defendant's request to instruct the jury on that defense with respect to the charge of manslaughter in the first degree with a firearm. The defendant also claimed that his conviction of both criminal possession of a firearm and criminal possession of ammunition violated the constitutional prohibition against double jeopardy. Held: The trial court's failure to provide the jury with a self-defense instruction for the charge of manslaughter in the first degree with a firearm violated the defendant's constitutional rights to due process and to present a defense, and, accordingly, this court reversed the judgment of conviction as to that charge and ordered a new trial on that charge only. Upon reviewing the rationale for justification defenses and the relevant case law from Connecticut and other states, this court concluded that, when the evidence so warrants, a trial court must instruct the jury on self-defense in connection with a reckless manslaughter charge, regardless of whether the victim is a bystander or the alleged aggressor. 352 Conn. 104 JUNE, 2025 105 St