## Facts

- Sharan Ann Williams was the mother of two young daughters who sometimes stayed with their grandmother and sometimes stayed with Williams and her boyfriend, Herbert Ronald Bowden.
- Bowden lived in a converted duplex that lacked a kitchen or bathroom, had no working utilities, and had minimal furnishings.
- About two weeks before the fire, the grandmother warned Williams and Bowden that taking the children there and using candles was “too dangerous,” citing fire risk.
- On the night of the incident, Williams took the children from the grandmother’s home (with utilities) to Bowden’s home (without electricity).
- A candle on a metal plate was used to light the children’s bedroom.
- Bowden agreed to supervise the children while Williams left; she stayed away for several hours past when she was expected to return.
- Bowden remained in the living room and left the candle burning so the children would not be in the dark; Williams typically extinguished the candle after the children fell asleep.
- A fire started in the early morning; Bowden awoke to screams, could not rescue the children, and both died.
- Williams was charged and convicted of injury to a child by criminal recklessness under Texas Penal Code § 22.04 and sentenced to fifteen years; the court of appeals affirmed.

## Issues

1. Whether the evidence was legally sufficient to prove Williams acted with criminal recklessness under Texas Penal Code § 22.04 by taking the children to a home without utilities and leaving them with a lit candle under Bowden’s supervision.
2. Whether the evidence was legally sufficient to prove Williams’s acts or omissions caused the children’s deaths for purposes of § 22.04.

## Decision

- The Texas Court of Criminal Appeals reversed the intermediate court’s judgment.
- The court held the evidence legally insufficient to prove a criminally culpable reckless mental state.
- The court also held the evidence legally insufficient to prove causation between Williams’s conduct and the deaths.
- The court rendered a judgment of acquittal.

## Legal Principles

- Criminal recklessness requires proof that the defendant was aware of, and consciously disregarded, a substantial and unjustifiable risk, and that the disregard was a gross deviation from ordinary care.
- Evidence showing poor judgment, substandard living conditions, or negligence does not, without more, establish criminal recklessness.
- The State must prove causation between the defendant’s conduct and the prohibited result; it is not enough that the conduct merely contributed to a generally hazardous setting.
- When the harmful result depends on an intervening actor’s conduct, the State must still prove the defendant’s conduct was a but-for cause and clearly sufficient to produce the result under the governing causation standard.

## Conclusion

The court concluded that transporting the children to a home without utilities and leaving them in a candle-lit bedroom under an adult caregiver’s supervision, even after a warning about candles, did not prove beyond a reasonable doubt that Williams consciously disregarded a substantial and unjustifiable risk or that her conduct caused the fatal fire; it therefore reversed and acquitted.


Williams v. State, 235 S.W.3d 742 (Tex. Crim. App. 2007)