B336210
Cal. Ct. App.Aug 25, 2025Background
- Kwame Williams was charged with multiple felonies, including attempted murder for a shooting outside a dollar store in Los Angeles in January 2022.
- Williams was identified via surveillance footage, officer identification, social media posts, and circumstantial evidence tying him to the scene and involved vehicle.
- Firearm toolmark evidence, linking cartridge cases from the dollar store shooting to a previous downtown shooting, was introduced via expert testimony.
- Williams was acquitted of attempted murder in the downtown shooting but convicted for the dollar store shooting; his claim on appeal focuses on alleged ineffective assistance of counsel regarding the forensic expert's testimony.
- On appeal, Williams argued his trial counsel should have challenged the admissibility and scientific reliability of the toolmark expert’s opinions.
- The Court of Appeal found insufficient evidence in the record to evaluate the scientific reliability or prejudice, and significant independent evidence linked Williams to the crime regardless of the expert's testimony.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Ineffective assistance for not objecting to expert | Attorney performance was reasonable | Counsel should have challenged scientific reliability of testimony | Williams did not show deficient performance or prejudice; conviction affirmed |
| Admissibility of toolmark expert testimony | Method is reliable and generally accepted | Testimony was scientifically invalid and inadmissible | No categorical inadmissibility shown; no basis in record to exclude testimony |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (sets the two-prong test for ineffective assistance of counsel: deficient performance and prejudice)
- People v. Kelly, 17 Cal.3d 24 (Cal. 1976) (expert scientific testimony admissible if generally accepted in the relevant scientific community)
- People v. Delgado, 2 Cal.5th 544 (Cal. 2017) (defendant bears burden to show counsel was deficient and prejudicial)
- Sargon Enterprises, Inc. v. Univ. of S. Cal., 55 Cal.4th 747 (Cal. 2012) (trial courts must act as gatekeepers to exclude speculative expert opinion)