State v. Williams

Summary

The court held that, when supported by the evidence, self-defense must be submitted to the jury as a complete defense to reckless first-degree manslaughter with a firearm, even when the deceased was a bystander rather than the person who initiated the attack. Because the evidence supported the instruction and the omission was not harmless beyond a reasonable doubt, the manslaughter conviction was reversed and remanded for a new trial. The court also held that simultaneous possession of a firearm and ammunition in one place and at one time under the same possession statute resulted in a double-jeopardy violation, requiring vacatur of the ammunition conviction.