- Court
- New York Supreme Court, Appellate Division, Second Department
- Case
- Williams v. State of New York
- Date
- June 3, 2026
- Slip Op. No.
- 2026 NY Slip Op 03472
Background
Claimant Shawn Williams was convicted of second-degree murder in connection with a shooting that occurred just after midnight on July 9, 1993, in the lobby of an apartment building in Brooklyn. The conviction rested primarily on the identification testimony of Margaret Smith-Leddy, a building resident who identified the claimant as the gunman. Williams was sentenced to twenty-five years to life. In 2014, Smith-Leddy signed an affidavit recanting her trial identification. Thereafter, the claimant moved pursuant to CPL 440.10 to vacate the judgment of conviction, and in 2018, the Supreme Court, Kings County, granted the motion and vacated the conviction. Williams then commenced this claim against the State of New York under Court of Claims Act section 8-b, seeking damages for unjust conviction and imprisonment. After a nonjury trial, the Court of Claims entered judgment in favor of the State, and Williams appealed.
Holding
The Appellate Division affirmed the judgment dismissing the claim. Under Court of Claims Act section 8-b, a claimant seeking damages for unjust conviction and imprisonment must demonstrate by clear and convincing evidence that he did not commit the crime charged or any lesser included offense. The Court found that Williams failed to meet this exacting burden. Although his conviction had been vacated based on the recantation of the key witness, vacatur of a conviction does not by itself establish that the claimant is actually innocent. The Court of Claims, after conducting a nonjury trial and weighing the evidence, concluded that the claimant did not establish his innocence by clear and convincing evidence, and the Appellate Division deferred to those findings as supported by the record.
Takeaways
A critical distinction exists between obtaining vacatur of a criminal conviction and proving actual innocence for purposes of a damages claim under Court of Claims Act section 8-b. Vacatur may be granted on procedural or constitutional grounds—such as a witness recantation that undermines confidence in the verdict—without any finding that the defendant was actually innocent. By contrast, a damages claim requires the claimant to affirmatively prove, by clear and convincing evidence, that he did not commit the offense. This is a significantly higher standard that demands more than just the absence of reliable evidence of guilt.
Why It Matters
This decision highlights the difficult path faced by exonerees seeking compensation under New York law. Even when a conviction is vacated after decades of imprisonment, the claimant must prove actual innocence by clear and convincing evidence at a separate civil trial to recover damages from the State. The ruling underscores that the recantation of an eyewitness—while sufficient to undermine the reliability of a criminal conviction—does not necessarily establish that the defendant was innocent. Advocates for wrongful conviction reform should take note that the burden of proof in unjust conviction claims remains one of the most stringent in New York civil litigation, requiring more than the creation of reasonable doubt about guilt.