People v. Williams
New York Court of Appeals
2025 NY Slip Op 00901
Legal Issue
The central legal issue in People v. Williams is whether the evidence presented at trial was legally sufficient to support Raymond Williams’s conviction for burglary in the third degree under New York Penal Law § 140.20. Specifically, the court examined whether Williams entered the CVS store unlawfully with the intent to commit a crime therein.
Facts
Background
Raymond Williams, the appellant, was charged with burglary in the third degree after entering a CVS store in Manhattan on January 19, 2017. Williams had previously signed a trespass notice barring him from entering any CVS location due to prior shoplifting incidents. On the day in question, Williams entered the store, took two cans of Red Bull energy drinks from a cooler, and walked toward the self-checkout area. He did not attempt to conceal the items or leave the store with them.
Events Leading to Arrest
A CVS employee recognized Williams as someone subject to the trespass notice and alerted the store manager. The manager confronted Williams, instructed him to return the items, and told him to leave the store. Williams complied, “slamming” the cans down before exiting. Surveillance footage captured Williams’s actions, including his movements inside the store and his interaction with the manager.
Trial and Conviction
At trial, the prosecution argued that Williams’s behavior—such as pausing before entering the store, glancing over his shoulder, and slamming the cans down—demonstrated furtive conduct indicative of an intent to steal. Additionally, the prosecution presented statements Williams made to police during an interview a month later, including admissions such as “I f—d up,” “I did it,” and “all [I] took was a [R]ed [B]ull.”
The jury convicted Williams of third-degree burglary, and he was sentenced as a second violent felony offender to the maximum term of three and a half to seven years in prison.
Court’s Holding
The Court of Appeals affirmed the conviction, holding that the evidence was legally sufficient to support the jury’s finding that Williams intended to commit a crime when he entered the CVS store. The court reasoned that:
- A rational jury could infer Williams’s knowledge of the unlawfulness of his entry based on the signed trespass notice and the CVS employee’s testimony.
- A rational jury could infer Williams’s intent to steal from his behavior inside the store, his interaction with the store manager, and his statements to police.
The court rejected Williams’s argument that innocent explanations for his conduct precluded a finding of guilt beyond a reasonable doubt. It emphasized that competing inferences from the evidence were for the jury to resolve.
Applicable Law
Burglary in the Third Degree
Under New York Penal Law § 140.20, a person is guilty of burglary in the third degree when they “knowingly enter or remain unlawfully in a building with intent to commit a crime therein.”
Legal Sufficiency of Evidence
A verdict is legally sufficient when, viewing the facts in the light most favorable to the prosecution, there is a valid line of reasoning and permissible inferences from which a rational jury could find the elements of the crime proved beyond a reasonable doubt (People v. Danielson, 9 NY3d 342 [2007]; People v. Acosta, 80 NY2d 665 [1993]).
Intent to Commit a Crime
Intent requires that the defendant’s conscious objective was to engage in conduct or cause a result described by the statute defining the offense (Penal Law § 15.05[1]). For burglary, the intent to commit a crime must exist at the time of unlawful entry (People v. Gaines, 74 NY2d 358 [1989]).
Corroboration of Confessions
Under CPL 60.50, a person may not be convicted solely upon evidence of a confession or admission without additional proof that the offense charged has been committed.
Key Terms for Better Understanding
- Burglary in the Third Degree: A felony offense involving unlawful entry into a building with the intent to commit a crime.
- Trespass Notice: A legal document barring an individual from entering specific premises due to prior misconduct.
- Intent: The conscious objective to engage in conduct or cause a specific result, as required by law.
- Furtive Conduct: Suspicious or secretive behavior that may indicate criminal intent.
- Legal Sufficiency: The standard for determining whether evidence presented at trial is adequate to support a conviction.
- Corroboration: Additional evidence required to support a confession or admission in criminal cases.
- Second Violent Felony Offender: A sentencing designation for individuals with prior violent felony convictions, subjecting them to enhanced penalties.
Analysis of the Dissenting Opinion
Chief Judge Wilson’s Perspective
Chief Judge Wilson dissented, arguing that the evidence was insufficient to prove Williams’s intent to steal beyond a reasonable doubt. He emphasized the following points:
- Williams’s actions—pausing before entering the store, glancing over his shoulder, and slamming the cans down—were ordinary and did not demonstrate criminal intent.
- Williams’s statements to police were inconsistent with the surveillance footage and could not reliably establish intent.
- The jury improperly relied on the trespass notice to infer intent, despite the court’s instructions limiting its use to proving unlawful entry.
Broader Implications
Wilson criticized the prosecution’s decision to charge Williams with felony burglary for attempting to take two cans of Red Bull, highlighting the disproportionate severity of the sentence. He argued that the case exemplified systemic issues in the criminal justice system, including the overcharging of petty offenses and the failure to address underlying issues such as addiction and homelessness.
Conclusion
The decision in People v. Williams underscores the legal standards for proving burglary in the third degree, particularly the elements of unlawful entry and intent to commit a crime. While the majority upheld the conviction based on the sufficiency of the evidence, the dissent raised important questions about fairness, proportionality, and the role of the criminal justice system in addressing societal issues.
This case serves as a reminder of the challenges in balancing public safety, individual accountability, and the need for systemic reform.