People v. Williams

(Modified upon denial of rehearing 12/13/14.) Defendant was convicted, after bench trial, of first-degree murder based on accountability theory. Evidence was insufficient to sustain conviction for first-degree as Defendant did not share any common criminal intent or design with any codefendants. Court’s finding that Defendant was conspiring with shooter conflicted with State’s theory of crime and court’s finding that Defendant was not in a gang. Thus, inference, which was sole legal basis for culpability, was demonstrably unreasonable. (HOWSE and FITZGERALD SMITH, concurring.)