Williams v. State

Williams (defendant) and Jones argued over a photo; Jones grabbed Williams's wallet and later attacked him with a lead pipe. Williams got a bow and arrow and pursued Jones, and though he shouted a warning, an arrow struck bystander Jewel Lyles, who was nine months pregnant. Lyles's baby was born alive but died shortly afterward from the injury, and Lyles also died. A jury convicted Williams of manslaughter for both deaths. On appeal, Williams argued the born-alive rule the court adopted should not apply to his conviction.

Whether, under the born-alive rule, the death of a child born alive but later dying from an injury inflicted in utero constitutes a homicide.