State v. Williams
2011 Mo. App. LEXIS 1553
Mo. Ct. App.2011Background
- Damon Williams and accomplices planned to rob a house for marijuana and money at 3610 Pimlico Drive in Columbia, MO.
- Participants Jaco, Washington, Williams, and others entered the home wearing hoodies; they demanded money and drugs.
- Bentley was upstairs; Jaco found money and marijuana; Williams went upstairs, gunfire occurred, Bentley was killed.
- Davis was threatened with a gun and forced to kneel; the group fled with stolen items, gun hidden, towels used to conceal faces.
- Evidence included a .380 shell casing, a gun recovered near the scene, and a towel with DNA mixture; Jaco, Jacobs, and Smith were ruled out as contributors; Williams and Washington were not excluded.
- After interrogation, Jaco and Washington surrendered; Jaco identified all participants; Williams surrendered later and initially denied involvement; trial resulted in convictions for first-degree murder, first-degree robbery, and armed criminal action.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of Detective Short’s testimony about Jaco’s statements | Williams argues it bolstered Jaco’s credibility improperly. | State contends statements were admissible to rehabilitate credibility. | Not error; statements admissible for rehabilitation. |
| Sua sponte setting aside guilty plea | Williams contends the court lacked authority to set aside after acceptance. | Creamer permits rejection before full acceptance; here court signaled non-acceptance prior to final decision. | Convictions affirmed; no reversible plain error. |
Key Cases Cited
- State v. Prince, 311 S.W.3d 327 (Mo.App. W.D.2010) (evidentiary abuse standard for trial court discretion)
- State v. Chism, 252 S.W.3d 178 (Mo. App. W.D.2008) (abuse of discretion in evidentiary rulings)
- State v. Tillman, 289 S.W.3d 282 (Mo.App. W.D.2009) (prejudice requirement for adverse evidence review)
- State v. Thompson, 112 S.W.3d 57 (Mo.App. W.D.2003) (prejudice standard for appellate review of improper evidence)
- State v. Ramsey, 864 S.W.2d 320 (Mo. banc 1993) (prior consistent statements admissible to rehabilitate credibility)
- State v. Robinson, 194 S.W.3d 379 (Mo.App. W.D.2006) (relevance of prior consistent statements to credibility after attack on credibility)
- Cole, 867 S.W.2d 685 (Mo.App. E.D.1993) (distinction on scope of prior consistent statements in impeachment)