Ronny Lee Williams v. State
12-15-00139-CR
Tex. App.Nov 16, 2015Background
- Ronny Lee Williams was tried by jury on four felonies from events of Sept. 11, 2013: aggravated robbery (victim 65+), burglary of a habitation, assault on a public servant, and possession of PCP (10.11 g).
- Facts: Williams (appearing intoxicated, wearing white shorts) was observed inside Morgan Bright’s home, assaulted Bright (who lost teeth), fled to a nearby playhouse/treehouse, resisted arrest, was tasered multiple times, and punched an officer. Officers recovered a bottle later shown to contain PCP.
- Two psychiatric experts examined Williams; both concluded he was not legally insane at the time and that PCP intoxication (voluntary) played a role. Williams did not testify.
- Jury convicted on all counts and assessed consecutive terms: possession 20 yrs; aggravated robbery 70 yrs; assault on public servant 10 yrs; burglary 8 yrs.
- Appellate counsel filed an Anders brief concluding no non-frivolous appellate issues after reviewing record; outlined two potential issues (sufficiency of evidence; ineffective assistance) and explained why each lacks merit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legal sufficiency of evidence supporting convictions | State: eyewitness testimony, physical injuries, officer testimony, and stipulated lab report established each element beyond a reasonable doubt | Williams: (potential) challenges to sufficiency — e.g., identity, weight of evidence, or elements not met | Appellate counsel: evidence legally sufficient; no non-frivolous sufficiency argument exists |
| Ineffective assistance of counsel at trial | State: trial counsel conducted reasonable investigation, used experts, cross-examined witnesses, and made strategic choices to mitigate punishment | Williams: (potential) counsel failed to object, failed to present mitigating evidence, or otherwise performed deficiently | Appellate counsel: record demonstrates plausible strategic bases; no showing under Strickland that outcome would differ — issue frivolous |
Key Cases Cited
- Anders v. California, 386 U.S. 738 (U.S. 1967) (requirements for counsel who concludes an appeal is frivolous)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (legal-sufficiency standard: evidence viewed in light most favorable to verdict)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
- Brooks v. State, 323 S.W.3d 893 (Tex. Crim. App. 2010) (standard of review for sufficiency in Texas)
- Clewis v. State, 922 S.W.2d 126 (Tex. Crim. App. 1996) (weight and sufficiency principles)
- McFarland v. State, 928 S.W.2d 482 (Tex. Crim. App. 1996) (presumption of counsel effectiveness; review of totality of representation)
- High v. State, 573 S.W.2d 807 (Tex. Crim. App. 1978) (procedural requirements when appellate counsel seeks to withdraw under Anders)
- Malik v. State, 953 S.W.2d 234 (Tex. Crim. App. 1997) (hypothetically correct jury charge/sufficiency framing)
