Sharan Ann Williams, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals of Texas held that the evidence was legally insufficient to support Sharan Williams's convictions for reckless injury to a child under Penal Code section 22.04, where she took her two young daughters from a house with working utilities to her boyfriend's utility-less duplex and left them asleep there with a lit candle under the boyfriend's care, and the children died in an accidental fire. Neither act involved the conscious disregard of a substantial and unjustifiable risk that recklessness requires—the boyfriend was shown to be a responsible caretaker, the grandmother's general warning was too unfocused to prove subjective awareness of a severe risk, and the boyfriend's failure to blow out the candle was not a reasonably foreseeable intervening cause, defeating but-for causation under section 6.04(a). The Court reversed the court of appeals and ordered an acquittal, declining to reach factual sufficiency. Presiding Judge Keller, joined by Judge Meyers, dissented, contending the risk was unjustifiable, the mother's failure to return as promised showed she would have prevented the tragedy, and the jury's verdict deserved deference.