State v. Williams: Extending the Statutory Justification of Self-Defense to Reckless Manslaughter Involving an Innocent Bystander

Introduction

Court: Supreme Court of Connecticut | Date: 10 June 2025

State v. Williams presented a “novel” question in Connecticut criminal law: whether a defendant who recklessly kills an innocent bystander while purportedly defending himself against an aggressor is entitled to the full statutory defense of self-defense, thereby shifting the burden to the State to disprove that defense beyond a reasonable doubt.

Robert J. Williams was convicted of (1) manslaughter in the first degree with a firearm, in violation of Conn. Gen. Stat. § 53a-55a(a), for the death of bystander Terry Smith and (2) criminal possession of ammunition under § 53a-217(a)(1). The majority opinion (not reproduced in the excerpt) reversed the manslaughter conviction and ordered a new trial, holding that the jury should have been instructed that the State must disprove self-defense. Justice D’Auria’s opinion—concurring in the vacatur of the ammunition count but dissenting on the manslaughter issue—vigorously opposed that holding, insisting that the statutory scheme (particularly § 53a-19 and § 53a-55) does not extend self-defense to reckless killings of non-aggressors.

Summary of the Judgment

Manslaughter Count: The majority reverses and remands for new trial because the jury was not instructed that the State bears the burden of disproving self-defense, even though the victim was a bystander and the charged mental state was recklessness.
Ammunition Count: All Justices agree to vacate the conviction on unrelated statutory grounds (Part II of the majority opinion).
Precedential Holding (majority): When evidence warrants, the statutory justification of self-defense under § 53a-19 is available to a defendant charged with reckless manslaughter, even where the decedent is an innocent third party; consequently, the State must disprove that defense beyond a reasonable doubt under § 53a-12(a).
Dissent (D’Auria, J.): The statutory language, the Model Penal Code, and the majority view in other jurisdictions limit self-defense to situations in which the person against whom force is used is the aggressor; therefore, no burden shifts to the State when the person killed is a bystander.

Analysis

A. Precedents Cited

State v. Hall, 213 Conn. 579 (1990) – Recognized self-defense may be charged with reckless manslaughter where the victim is the aggressor. Majority reads Hall expansively; dissent reads it narrowly.
Commonwealth v. Fowlin, 551 Pa. 414 (1998) – Pennsylvania case permitting self-defense to negate recklessness when a bystander is killed; majority finds it persuasive, dissent calls it a minority approach.
Morris v. Platt, 32 Conn. 75 (1864) – Early Connecticut authority that accidental injury to third persons is excusable only where the actor is not reckless; relied on by dissent.
Model Penal Code § 3.09(3) – Provides that justification is unavailable when actor recklessly injures an innocent person. Dissent urges adoption; majority distinguishes.
State v. Courchesne, 296 Conn. 622 (2010); State v. Salz, 226 Conn. 20 (1993); and others – cited for principles of statutory interpretation and subjective/objective components of self-defense and recklessness.

B. Legal Reasoning

1. Majority (as described in Dissent)

The majority concludes that § 53a-19(a) contains no textual bar to applying self-defense where the force accidentally strikes a third person; it focuses on whether the defendant’s use of force was reasonable, not on who was struck. It relies on policy concerns—jury comprehension, fairness, and consistency with transferred intent doctrines—and analogizes to jurisdictions like Pennsylvania that allow the defense in similar contexts.

2. Dissent (Justice D’Auria)

Textual analysis: § 53a-19(a) speaks of “a person” (the defendant) using deadly force on “another person,” and justifies that force only if “such other person” is using or about to use deadly force. The phraseology necessarily limits the defense to the aggressor-target dyad; a third party falls outside the statute.
Interaction with Recklessness: Because reckless manslaughter is an unintentional crime, it conflicts with the intentional element historically embedded in self-defense. Any self-defense evidence merely negates recklessness; it does not create a statutory justification that shifts the burden.
Model Penal Code & Majority Rule: Most jurisdictions deny the defense where the innocent bystander is killed recklessly; Connecticut legislators incorporated MPC structure and must have intended the same limitation.
Hall Distinguished: Hall involved the aggressor as the decedent; it did not consider bystander scenarios nor the burden-shifting question.

C. Potential Impact

Prosecutorial Burden: In Connecticut, prosecutors must now anticipate self-defense charges in virtually every shooting case, even where only recklessness is alleged and the victim is not the aggressor, and must be prepared to disprove the defense beyond a reasonable doubt.
Defense Strategy: Defense counsel will likely assert self-defense more aggressively in negligent/reckless homicide cases, seeking jury instructions that force the State to carry the burden.
Jury Instructions: Pattern instructions will need revision to include self-defense language for reckless manslaughter/bystander fact patterns.
Legislative Response: The dissent’s statutory argument may prompt legislative clarification—either codifying the majority’s rule or reinstating the limitation urged by Justice D’Auria.
Appellate Litigation: Williams invites future appeals on the scope of “reasonably believes” and “deadly physical force,” and on the definition of “bystander” versus “third person” within § 53a-19.

Complex Concepts Simplified

Self-Defense (Justification) vs. Negation: A justification excuses conduct that would otherwise be criminal and places the burden on the State to disprove it. A negation argument merely says an element of the crime (e.g., recklessness) is missing; the defendant bears no additional burden but gains no burden-shift.
Recklessness: Acting while consciously disregarding a substantial, unjustifiable risk—less culpable than intent but more than mere negligence.
Transferred Intent: When a defendant intends to harm person A but accidentally harms person B, the intent “transfers.” Williams concerns whether the *justification* of self-defense likewise “transfers.”
Burdens of Proof: Under § 53a-12(a), once a non-affirmative defense like self-defense is “in issue,” the State must disprove it beyond a reasonable doubt.
Subjective–Objective Test: Self-defense requires that the defendant subjectively believe force is necessary and that this belief be objectively reasonable under the circumstances.

Conclusion

State v. Williams establishes a significant new precedent in Connecticut: even when a defendant is prosecuted for reckless manslaughter arising from the death of an innocent bystander, he is entitled to a full statutory self-defense instruction, and the State must disprove that defense beyond a reasonable doubt if the evidence supports it. The sharply reasoned dissent underscores the tension between statutory text, majority national practice, and the court’s policy-driven expansion. Going forward, practitioners must adjust charging decisions, trial strategies, and jury instructions to account for this broadened application of self-defense, while observers watch for potential legislative or further judicial refinement.