State v. Williams, 2025 ND 46

Benjamin Williams was charged with murder and unlawful possession of a firearm after a fatal shooting in Bismarck, North Dakota in October 2022.
Law enforcement collected physical evidence at the crime scene, and Williams’s jury trial began April 1, 2024.
During trial preparations, the State obtained new, undisclosed testimony from a key witness and failed to disclose certain employment records of its forensic examiner, Dr. Barrie Miller.
The jury convicted Williams on both counts, and he was sentenced to life without parole for murder, with a concurrent five-year term for firearm possession.
Williams appealed the convictions, primarily alleging Brady violations, prosecutorial misconduct, and discovery failures.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exclusion of new witness testimony (Brady violation)	New witness information was not disclosed and could impact credibility (Brady violation)	Information was obtainable by due diligence; Williams knew witness identity	No Brady violation; denial of motion to exclude
Non-disclosure of forensic examiner's employment records	Suppression of Dr. Miller’s employment issues violated discovery and Brady obligations	Issue was not preserved below (focused at trial only on sanctions, not violation)	Not considered; not preserved for appellate review
Prosecutorial misconduct in closing argument (DNA evidence)	State improperly argued Williams was a possible minor DNA contributor in closing	Argued statements were based on the evidence presented	No prosecutorial misconduct

Brady v. Maryland, 373 U.S. 83 (1963) (suppression of material, exculpatory evidence violates due process)
State v. Muhle, 737 N.W.2d 647 (N.D. 2007) (Brady applies to impeachment evidence; due diligence required)
State v. Kolstad, 942 N.W.2d 865 (N.D. 2020) (Brady materiality and analysis framework)
State v. Chatman, 872 N.W.2d 595 (N.D. 2015) (issues not raised in trial court generally not reviewed on appeal)