State of Tennessee v. Jimmy Williams
W2016-00946-CCA-R3-CD
| Tenn. Crim. App. | Sep 13, 2017Background
- On July 27, 2008, the victim was assaulted in a grassy area; she testified Defendant grabbed, struck, and forced her to perform oral sex and struck her with a box cutter; officers found a box cutter and photos showed bruising and blood.
- Victim identified Williams six years later from photographs; DNA testing found the Defendant’s blood on the victim’s shirt and the box cutter contained a mixture that did not exclude the Defendant.
- Witnesses heard the victim screaming and called police; officers pursued and arrested the Defendant fleeing the scene.
- Jury acquitted Williams of aggravated rape but convicted him of aggravated assault (display/use of a deadly weapon causing injury).
- At sentencing the State sought to classify Williams as a career offender based on prior convictions; the State’s formal notice in this specific case was late, but a timely notice had been filed in a companion case pending concurrently.
- Trial court and the Court of Criminal Appeals upheld the conviction and the career-offender sentence, finding sufficient evidence and adequate notice (actual/constructive) of intent to seek enhanced punishment.
Issues
| Issue | State's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for aggravated assault | Evidence (victim injuries, box cutter, flight, witnesses, blood/DNA) supports conviction | Conviction relies solely on victim's testimony; other witnesses did not see strikes | Affirmed: evidence sufficient for aggravated assault (jury credited victim) |
| Validity/timeliness of notice to seek enhanced sentence | Timely notice in companion case provided actual/constructive notice; no prejudice shown | Notice in this case was filed late, prejudicing ability to seek continuance or change trial strategy | Affirmed: defendant had actual/constructive notice; no prejudice; career-offender classification proper |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence review)
- State v. Livingston, 197 S.W.3d 710 (Tenn. 2006) (purpose and minimal requirements of notice to seek enhanced sentencing)
- State v. Carter, 121 S.W.3d 579 (Tenn. 2003) (defendant must show prejudice from late/defective notice)
- State v. Debro, 787 S.W.2d 932 (Tenn. Crim. App. 1989) (constructive notice via companion-case filing can satisfy notice requirement)
- Bolin v. State, 405 S.W.2d 768 (Tenn. 1966) (trial judge/jury credibility determinations entitled to deference)