State of Tennessee v. Joshua Hill-Williams, W2015-01743-CCA-R3-CD

Background

On Dec. 21, 2013 Joshua Hill-Williams shot and killed Evvann "Juice" Harris in an apartment; Hill-Williams was convicted by a Shelby County jury of first-degree premeditated murder and sentenced to life.
Earlier (Dec. 16) Harris allegedly stole Hill-Williams's Glock 19; Hill-Williams reported the theft to police, identified Harris in a photo array, and received threats that worried him.
On Dec. 21 Hill-Williams went to an apartment where Harris was present, entered armed with a Beretta, asked about his gun, fired a first shot as Harris stood, then shot additional times; Harris was hit nine times (including shots to the back) and a Glock with Hill-Williams's serial number was found on Harris's person.
Multiple witnesses placed Hill-Williams at the scene with a gun and saw persons fleeing in a red Camaro; Hill-Williams made statements (to 911 and officers) that he killed Harris after Harris "upped on" him and later texted "I just killed him. He up on me. Erase this message. I love you." Forensics matched the Beretta to the casings/bullets.
At trial Hill-Williams claimed self-defense (fear due to prior threat and Harris allegedly reaching for a weapon). Defense sought to elicit the victim's gang membership; the trial court excluded gang membership evidence but allowed reputation-for-violence testimony. The court admitted a State summary and a full dump of Hill-Williams's texts; the court also gave a jury instruction on flight.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to support first-degree murder	State: evidence (shooting facts, multiple wounds including back, post-shooting statements, motive from theft/texts) supports premeditation and rejects self-defense	Hill-Williams: acted in self-defense because Harris pointed/was drawing a gun and had threatened him after the theft	Affirmed conviction: viewing evidence in the light most favorable to the State, a rational jury could find premeditation and reject self-defense
Exclusion of victim's gang membership	State: gang membership irrelevant/prejudicial to self-defense issue; reputation for violence (not gang membership) suffices	Hill-Williams: gang membership was relevant to his state of mind and to show victim's violent character/first aggressor; State "opened the door" by favorable background questions	Exclusion affirmed: gang membership irrelevant to the defendant's stated fear; trial court properly admitted reputation-for-violence testimony but excluded specific gang membership as unduly prejudicial
Admission of received text messages and State's summary	State: received texts were not hearsay because offered to provide context for Hill-Williams's outgoing texts; summary admissible and full dump also provided	Hill-Williams: texts received are hearsay; State's summary was incomplete/misleading compared to full dump	Admission affirmed: received texts used for context (not for truth) and the court admitted both the summary and the full text dump (fairness under Rule 106); any hearsay error would be harmless
Flight jury instruction	State: evidence of leaving scene + furtive conduct (fleeing in car, warm car, delay before turning self in) supports flight inference	Hill-Williams: left to avoid retribution and later surrendered; he cooperated and did not hide from police	Instruction affirmed: sufficient evidence for flight (leaving scene plus evasive conduct) and the instruction properly left weight and explanation to the jury

Key Cases Cited

Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of the evidence)
State v. Cabbage, 571 S.W.2d 832 (appellate view of evidence in strongest light for prosecution)
State v. Bland, 958 S.W.2d 651 (jury resolves credibility and factual issues)
State v. Davidson, 121 S.W.3d 600 (premeditation is a jury question)
State v. Nichols, 24 S.W.3d 297 (factors from which premeditation may be inferred)
State v. Leach, 148 S.W.3d 42 (motive and multiple weapons as inferences of premeditation)
State v. Tuggle, 639 S.W.2d 913 (defendant's burden to show insufficiency on appeal)
State v. Hall, 976 S.W.2d 121 (guilty verdict may rest on direct or circumstantial evidence)
State v. Dorantes, 331 S.W.3d 370 (same standard for circumstantial evidence)
State v. Sims, 45 S.W.3d 1 (State must disprove self-defense when raised)
State v. Clifton, 880 S.W.2d 737 (self-defense is a jury question)
State v. Ivy, 868 S.W.2d 724 (self-defense jury considerations)
State v. Farner, 66 S.W.3d 188 (trial court duty to charge applicable law fully)
State v. Burns, 979 S.W.2d 279 (flight instruction requires evidence of leaving and concealment/evasion)
State v. Whittenmeir, 725 S.W.2d 686 (both departure and subsequent concealment required for flight inference)