Manitoba’s highest court has ordered a new trial for a man convicted of killing a stranger in an unprovoked knife attack while high on meth.
Rodney Williams stood trial for second-degree murder in the June 2019 slaying of 51-year-old Robert Donaldson. He was convicted of the lesser offence of manslaughter after a judge ruled Williams had been in the grip of a meth psychosis that meant he was unable to form the intent to kill.
Williams was sentenced last spring to life in prison with no chance of parole for seven years. The minimum sentence for second-degree murder is life in prison with no chance of parole for at least 10 years.
Robert Donaldson, 51, was fatally stabbed when he a friend were walking near the intersection of Sherbrook Street and Sara Avenue on a June evening in 2019. (Facebook)
The Crown appealed Williams’ acquittal on the original charge and on Friday the Manitoba Court of Appeal ordered a new trial.
The court ruled King’s Bench Justice Shauna McCarthy failed to properly assess whether Williams had the required state of mind for murder, and instead “abdicated” that role to forensic psychiatrist Dr. Jeffrey Waldman, an expert witness for the defence.
Waldman had testified that Williams’ use of meth triggered his psychosis and that Williams believed Donaldson wanted to cause him harm.
“By attacking the victim, he believed he was acting in his defence, and in my opinion, was unable to develop intent as he was acting impulsively in the context of paranoia and intoxication with meth, along with other intoxicating substances,” Waldman wrote in a psychiatric assessment provided to the court.
The Crown argued the evidence showed Williams deliberately attacked Donaldson and that even in the grip of meth, he would have known that stabbing Donaldson in the chest would likely cause his death.
The appeal court said McCarthy failed to assess the entirety of the evidence pointing to Williams’ state of mind.
“This cannot be delegated to an expert by merely adopting the expert’s opinion on intent,” Justice Jennifer Pfuetzner wrote in a 16-page decision on behalf of the appeal court. “Regrettably, that is what occurred here.”
McCarthy allowed Waldman to “usurp” her responsibility to determine the legal question of Williams’ state of mind, and did not perform her own independent analysis, Pfuetzner said.
“The trial judge lost focus on the only question that mattered: whether the accused foresaw that stabbing the victim could kill him,” Pfuetzner wrote. “Instead, she focused on the question of whether or not the accused was in a state of methamphetamine-induced psychosis, believing that if he was, he could not have the mens rea for murder. Drug-induced psychosis does not necessarily equal lack of foresight. Specific relevant evidence in respect of foresight must be analyzed in order to make the determination.”
The trial was told Donaldson and a friend were walking near the intersection of Sherbrook Street and Sara Avenue, shortly before 9 p.m., when they crossed paths with Williams and another man. Williams yelled at Donaldson before pulling a knife from his pants, and chased Donaldson and his friend north toward Sara Avenue.
Rodney Williams was sentenced last spring to life in prison with no chance of parole for seven years for the deadly stabbing (Sasha Sefter / Winnipeg Free Press files)
Williams cut Davidson once in the ribs before a passing motorist tried to intervene and gave Donaldson and his friend a baseball bat and steering wheel anti-theft device (club) to defend themselves.
As Donaldson’s friend and the motorist tried to keep Williams at bay, Williams broke through their defences and stabbed Donaldson several more times, once fatally in the chest.
Two witnesses provided first aid, but he died within minutes.
Williams returned to his Sherbrook Street apartment and police arrested him a short time later.
In 2009, Williams, then 24, was sentenced to 18 years in prison after pleading guilty to manslaughter for stabbing a man to death three years earlier, following a party at Hollow Water First Nation.
Court was told Williams stabbed Leslie Moneyas five times, including four times in the back. He was granted statutory release in 2017.
Dean Pritchard
Courts reporter
Someone once said a journalist is just a reporter in a good suit. Dean Pritchard doesn’t own a good suit. But he knows a good lawsuit.
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