Marcus Rashad Williams v. the State of Texas
02-24-00028-CR
| Tex. App. | Nov 7, 2024Background
- Marcus Rashad Williams was convicted by a jury of murdering Lawrence Garcia Jr. under sudden passion by shooting him with a firearm.
- The shooting occurred after a physical altercation involving Garcia and Cristina Watkins (Williams's girlfriend) outside T.C.'s house.
- Witness J.C., familiar with Williams from previous visits to Watkins’s house, identified Williams as the shooter both in a photo lineup and later in court; A.H., an uninvolved passenger, was unable to identify Williams until viewing the third lineup and did not identify him in court.
- Williams filed a pretrial motion to suppress J.C.’s and A.H.’s identification evidence, which was denied, although a running objection was granted.
- Williams also challenged the trial court's refusal to strike a potential juror (V.M. One) for cause based on perceived bias toward police testimony; the challenge was denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Pretrial photo lineup was impermissibly suggestive | Williams: Lineup improper because J.C. helped find Williams's photo, tainting identification. | State: Photo ascertained from J.C.’s personal knowledge, not police action; not impermissibly suggestive. | Not impermissibly suggestive; identification admissible. |
| In-court identification tainted by pretrial events | Williams: In-court ID should be suppressed as the lineup tainted witness's memory. | State: No police misconduct and J.C.’s identification based on personal knowledge. | Identification admissible; lineup process appropriate. |
| Denial of challenge for cause to juror | Williams: Juror V.M. One was biased in favor of law enforcement testimony, warranting exclusion for cause. | State: Juror open-minded, did not express an absolute bias, and affirmed they would follow the law as instructed. | No abuse of discretion; challenge for cause properly denied. |
Key Cases Cited
- Neil v. Biggers, 409 U.S. 188 (due-process standard governs admissibility of identification procedures)
- Simmons v. United States, 390 U.S. 377 (pretrial identification may be so suggestive as to deny due process)
- Barley v. State, 906 S.W.2d 27 (Texas standard for evaluating suggestiveness and reliability of identifications)
- Feldman v. State, 71 S.W.3d 738 (trial court discretion in assessing juror bias and ability to be impartial)
- Jones v. State, 982 S.W.2d 386 (jurors need not have perfect impartiality; slight preference for certain witnesses not enough to strike for cause)