State v. Williams

Summary

The Supreme Court of Louisiana affirmed Allen Scott Williams' hit-and-run conviction and seven-year sentence at hard labor, holding the evidence sufficient under Jackson v. Virginia to prove every element of LSA-R.S. 14:100: that he caused the fatal accident although his vehicle never contacted the victim's, that he failed to stop at the scene, that his anonymous telephone report to the sheriff's office did not satisfy the 'give his identity' element, and that leaving a victim trapped in a burning vehicle without returning was not 'reasonable aid.' Construing R.S. 14:100(B)(1) under R.S. 14:3's 'genuine construction' directive and adopting State v. Agee, the court held a driver who reports an accident to police must identify himself, and it found general intent established by the very doing of the proscribed acts. The court also held the seven-year term, within the ten-year maximum of R.S. 14:100(C)(2), reflected no manifest abuse of the trial court's wide sentencing discretion. Chief Justice Calogero and Justice Weimer dissented, contending the statute's disjunctive 'or' meant the anonymous report satisfied the identity element and the evidence was insufficient; Justices Victory and Knoll concurred in the result.