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Ronny Lee Williams v. State
12-15-00140-CR
| Tex. App. | Nov 16, 2015
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Background

  • Ronny Lee Williams was tried by jury on four felonies from Nacogdoches County: aggravated robbery, burglary of a habitation, assault on a public servant, and possession of a controlled substance; jury convicted on all counts and imposed multi‑year sentences.
  • Incident (Sept. 11, 2013): eyewitnesses found an older victim (Morgan Bright) assaulted inside his home; Williams was seen leaving wearing only shorts and later found hiding in a child’s playhouse/treehouse.
  • Police used TASERs (ineffective), Williams resisted and struck an officer; officers recovered a pair of white shorts containing a bottle later tested and stipulated to contain 10.11 grams of PCP.
  • Two forensic psychiatrists examined Williams; both concluded voluntary PCP use and that he was not legally insane at the time of offenses.
  • Trial counsel stipulated to the PCP lab report and medical records, presented cross‑examination and mitigation evidence at punishment (including prior crimes and prior PCP incidents); Williams did not testify.
  • Appellate counsel filed an Anders brief concluding no nonfrivolous grounds for appeal after considering (1) legal sufficiency of the evidence and (2) ineffective assistance of counsel claims.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Legal sufficiency of evidence (guilt on all counts) State: eyewitness ID, victim’s age/injury, officer assault, and stipulated PCP lab report establish elements of aggravated robbery, burglary, assault on a public servant, and possession. Williams: (potential) challenge that evidence was insufficient to prove elements beyond a reasonable doubt. Court (per Anders brief): record shows ample evidence; sufficiency challenge would be frivolous.
Ineffective assistance of counsel Williams: (potential) trial counsel allegedly failed in representation (e.g., stipulations, failure to object, investigation) undermining fairness. Trial counsel: conducted investigations into competency/insanity, consulted experts, cross‑examined witnesses, and appeared to pursue mitigation strategy; no record evidence of deficient performance or prejudice. Court (per Anders brief): record does not show Strickland deficiency or prejudice; ineffectiveness claim would be frivolous and better raised in habeas if factual development needed.

Key Cases Cited

  • Anders v. California, 386 U.S. 738 (U.S. 1967) (procedural requirements when appointed counsel believes appeal frivolous)
  • Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (legal sufficiency standard: review 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) (Jackson standard as sole sufficiency test in Texas)
  • Clewis v. State, 922 S.W.2d 126 (Tex. Crim. App. 1996) (review of evidentiary weight and sufficiency)
  • McFarland v. State, 928 S.W.2d 482 (Tex. Crim. App. 1996) (deference to counsel’s performance; totality of representation)
  • High v. State, 573 S.W.2d 807 (Tex. Crim. App. 1978) (Anders‑type procedures in Texas)
Read the full case

Case Details

Case Name: Ronny Lee Williams v. State
Court Name: Court of Appeals of Texas
Date Published: Nov 16, 2015
Docket Number: 12-15-00140-CR
Court Abbreviation: Tex. App.