United States v. Williams

In May 2003, Tyrone Mapletoft Williams, a commercial truck driver, transported 74 unlawful aliens from Harlingen, Texas, to Victoria, Texas. During the trip, he left the aliens locked in the trailer of his tractor–trailer without activating the trailer’s air conditioning unit; as a result, 19 aliens died of dehydration, hyperthermia, suffocation, and mechanical asphyxia. Williams was convicted of 39 separate counts arising out of that trip. For the 20 counts that were capital charges, the Federal Death Penalty Act contemplated that the jury would determine the appropriate sentence if it first found a threshold intent that would justify imposing a sentence of death. The applicable threshold intent required that Williams have engaged in an “act of violence” in committing the capital offenses. Following the district court’s instructions, the jury found that Williams had committed the requisite act of violence but that he should be sentenced to life imprisonment. We conclude that the district court erred in its definition of act of violence and that, under the correct definition, the evidence at trial cannot support a finding that the requisite threshold intent was met. While we affirm Williams’s convictions and his sentences to terms of years, we vacate his life sentences and remand for resentencing by the district court.

I. BACKGROUND