People v. Williams

A young female told police that Martin Williams and two other young males (defendants) forced her to get into a car by threatening to hurt her if she did not cooperate. The female said that she tried to be friendly with Williams in the car in order to get on his good side and be allowed to leave. However, the female’s repeated requests to be let out of the car were denied. The female said that she was then taken to Williams’s apartment, where she was locked inside and forced to perform sexual acts with all three males. The group then got back into a car, where the female said she was forced to perform an additional sex act with Williams before being released at a train station. Once released, the female immediately reported the incident to a police officer, and all three males were charged with first-degree rape and sodomy. Williams testified at trial, claiming that the female had been flirty and friendly, that she had several opportunities to leave if she had wanted to, and that he believed that she had consented to the sex acts. Williams’s attorney requested a jury instruction about intent, arguing that a defendant’s sincere, mistaken belief that a victim had consented meant that the defendant lacked the necessary intent to commit first-degree rape. Outside the jury’s presence, the trial judge told the attorneys that a rape charge required only a showing of action and a nonconsensual sex act, and that the defendant’s mens rea and intent were irrelevant. When the judge gave instructions to the jury, the instructions contained nothing about intent and stated that rape occurred if a defendant forcibly compelled a person to submit to sexual acts. The jury convicted all three males of first-degree rape and sodomy. On appeal, Williams argued that the jury should have been instructed that Williams lacked the criminal intent to commit rape if he mistakenly believed that the victim had consented. The appellate court confirmed the conviction, and New York’s highest court agreed to review the matter.