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