Williams v. State

Sharan Ann Williams (defendant) had two daughters. Her mother regularly watched them and kept them in her home overnight. One day, Williams picked up the girls from her mother’s home so that they could spend the night with her at her boyfriend’s home. Her boyfriend lived in a rundown duplex without running electricity or water. After dropping off the girls, Williams’s boyfriend agreed to watch the girls while Williams went to the store to buy snacks. Beforehand, they put the girls to bed with a lit candle in the bedroom, sitting on a metal plate. Williams left, and her boyfriend stayed at the home in the living-room area. He left the candle burning because he did not want the girls to be in the dark. Williams usually blew out the candle when the girls fell asleep, but on that night, she stayed out for several hours, well past the time she was due to return. Her boyfriend fell asleep on the couch waiting and woke up hours later to screams. He saw that the girls’ bedroom was on fire and tried to get them out but was unsuccessful. The girls died in the fire. Williams was charged and convicted of injury to a child through criminal recklessness based on the state’s argument that she acted recklessly by taking the girls from her mother’s home with utilities to a home without utilities and by burning a candle in their room. Williams appealed.