Alison Nicole Williams v. State of Mississippi
252 So. 3d 1067
Miss. Ct. App.2017Background
- Alison N. Williams pleaded guilty to armed robbery on June 29, 2012, and was sentenced to 10 years in MDOC plus 10 years postrelease supervision.
- Williams filed a first PCR in November 2013; the trial court denied it and this Court affirmed, noting she had not raised an involuntary-plea claim in the first PCR.
- In September 2015 Williams filed a second PCR asserting her plea was involuntary because she was mentally ill and affected by prescription drugs at plea and sentencing; she attached medical records, a pharmacist affidavit, a psychologist letter, and other documents.
- The trial court denied the second PCR as a successive writ under Miss. Code Ann. § 99-39-23(6), finding the submitted materials were not newly discovered evidence and did not credibly show incompetency at the plea hearing.
- The court relied on the plea transcript (Williams denied being under the influence and affirmatively acknowledged understanding the proceedings) and concluded Williams failed to meet exceptions to the successive-writ bar; Williams appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams' second PCR is barred as a successive writ under § 99-39-23(6) | Williams: evidence (medical records, pharmacist affidavit, psychologist letter) was not reasonably discoverable and is ‘‘newly discovered’’; thus exception applies | State: Williams already could have discovered or raised these claims earlier; materials are not newly discovered and she failed to meet the statutory exception | Held: Successive-writ bar applies; Williams did not prove exception for newly discovered evidence |
| Whether submitted evidence proves incompetency at plea (merits) | Williams: medications/mental illness rendered plea involuntary and not knowingly made | State: Plea transcript and plea petition show Williams understood proceedings and denied impairment | Held: Court found no credible evidence of incompetency at plea; plea was knowing and voluntary |
| Whether Coleman (intervening decision) exempts Williams' second PCR | Williams: Coleman requires competency inquiry and is an intervening decision affecting her case | State: Coleman was decided before Williams' first PCR and thus is not an intervening decision; even if applied, it would not have altered outcome | Held: Coleman is not an intervening decision for this motion and would not have changed the result |
| Whether Williams met the four-factor newly discovered evidence test (Pittman/Meeks) | Williams: her evidence would probably change the outcome and was not discoverable earlier | State: Evidence was discoverable with due diligence and is not practically conclusive of incompetency | Held: Williams failed to satisfy the newly discovered evidence test; all elements not met |
Key Cases Cited
- Williams v. State, 163 So. 3d 993 (Miss. Ct. App. 2015) (prior appellate decision addressing Williams's first PCR and procedural bar)
- Smith v. State, 149 So. 3d 1027 (Miss. 2014) (discussing competency claims and UPCCRA exceptions)
- Coleman v. State, 127 So. 3d 161 (Miss. 2013) (addressing competency procedures relied on by Williams)
- Pittman v. State, 121 So. 3d 253 (Miss. Ct. App. 2013) (articulating newly discovered evidence test)
- Meeks v. State, 781 So. 2d 109 (Miss. 2001) (defining four-factor standard for newly discovered evidence)
- Lockett v. State, 656 So. 2d 76 (Miss. 1995) (intervening-decision principle where decision was available earlier)