WESLEY L. WILLIAMS, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Wesley Williams was convicted of second-degree murder for fatally stabbing Troy Doolin during a fight. The court reversed, holding that the evidence supported only manslaughter because the state failed to prove the depraved mind element required for second-degree murder.
The court reversed the conviction and held that although the jury could reject Williams's self-defense claim based on his excessive use of a knife against an unarmed opponent, the state failed to present a prima facie case of second-degree murder because it presented no evidence that Williams acted with the required depraved mind or ill will, hatred, spite, or evil intent.
[1] A conviction for second-degree murder cannot stand if the evidence presented does not establish the elements of a depraved mind or ill will, hatred, spite, or evil intent…
[2] Evidence that a defendant used a knife to end a fight with an unarmed, intoxicated aggressor may be considered excessive force, but does not necessarily prove second-degr…
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“the appellant's use of a knife to end the fight or ward off further attack from Doolin can be considered excessive, especially since Doolin was unarmed. It was this evidence which allowed the jury to reject the appellant's theory of self-defense. However, the appellant's acts did not evince a depraved mind”
Establishes that excessive use of force in self-defense does not automatically constitute second-degree murder without proof of a depraved mind
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Join FLexlaw to unlock all legal intelligenceWilliams rented a room from Doolin, who was belligerently drunk and initiated a physical fight with Williams in the backyard. Police were called twice…
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DANAHY, Acting Chief Judge.
The appellant was convicted of the second degree murder of Troy Doolin, the owner of the home in which the appellant rented a room. He argues that the trial court erred in submitting the second degree murder charge to the jury since, at most, the evidence proved only the crime of manslaughter. We agree and reverse based on McDaniel v. State, 620 So. 2d 1308 (Fla. 4th DCA 1993), and the cases cited therein.
The evidence adduced at trial showed that the victim, Doolin, was belligerently drunk the day in question and started the fight with the appellant. The appellant was recuperating from an operation on his arm several weeks before to repair serious damage from a previous auto accident. The entire incident began in the backyard of the Doolin home with Doolin’s behavior necessitating that the police be called to subdue him. After the police left the second time, Doolin continued to press the fight with the appellant, moving it inside, to both the appellant’s room and the hallway outside it. After using their fists on each other for some time, the appellant pulled his knife from its holder on his belt and stabbed Doolin in the abdomen, fatally wounding him. It is undisputed that at all times the victim used no weapon before the appellant stabbed him. Like . McDaniel, we find that the appellant’s use of a knife to end the fight or ward off further attack from Doolin can be considered excessive, especially since Doolin was unarmed. It was this evidence which allowed the jury to reject the appellant’s theory of self-defense.
However, the appellant’s acts did not evince a depraved mind, and the state presented no evidence showing that the appellant acted out of ill will, hatred, spite, or an evil intent, thus failing to present a prima facie case of second degree murder. We, therefore, reverse the appellant’s conviction and remand with instructions that the trial court adjudicate him guilty of manslaughter and resentence him accordingly.
We find no error in the remaining points the appellant raised. Reversed and remanded for further proceedings.
SCHOONOVER and QUINCE, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
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Light v. State, 841 So. 2d 623 (Fla. 2d DCA 2003)…s behavior itself is insufficient from which to infer any malice. Moreover, other cases demonstrate that an impulsive overreaction to an attack or injury is itself insufficient to prove ill will, hatred, spite, or evil intent. See Williams v. State, 674 So. 2d 177 (Fla. 2d DCA 1996); McDaniel v. State, 620 So. 2d 1308 (Fla. 4th DCA 1993). Although exceptions exist, the crime of second-degree murder is normally committed by a person who knows the victim and has had time to develop a level of enmity toward the…
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Wiley v. State, 60 So. 3d 588 (Fla. 4th DCA 2011)…mpulsive overreaction to an attack or injury is itself insufficient to prove ill will, hatred, spite, or evil intent.” Light v. State, 841 So. 2d 623, 626 (Fla. 2d DCA 2003); McDaniel v. State, 620 So. 2d 1308 (Fla. 4th DCA 1993); Williams v. State, 674 So. 2d 177, 178 (Fla. 2d DCA 1996). Further, “[ajlthough exceptions exist, the crime of second-degree murder is normally committed by a person who knows the victim and has had time to develop a level of enmity toward the victim,” and “[h]atred, spite, evil int…
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Bellamy v. State, 977 So. 2d 682 (Fla. 2d DCA 2008)…le the State’s evidence may have proved an “impulsive overreaction to an attack or injury,” it was insufficient to prove ill will, hatred, spite, or evil intent. See Light v. State, 841 So. 2d 623, 626 (Fla. 2d DCA 2003); see also Williams v. State, 674 So. 2d 177 (Fla. 2d DCA 1996); McDaniel v. State, 620 So. 2d 1308 (Fla. 4th DCA 1993). Accordingly, we reverse Bellamy’s convictions for second-degree murder and attempted second-degree murder and remand with directions to enter a judgment of conviction for ma…
Previewing 3 of 7 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- McDANIEL v. State, 620 So. 2d 1308 (Fla. 4th DCA 1993)
- Hostzclaw v. State, 620 So. 2d 1308 (Fla. 4th DCA 1993)