State v. Williams
366 S.W.3d 609
| Mo. Ct. App. | 2012Background
- Williams was convicted in 2002 of second-degree murder, first-degree assault, and two armed criminal action counts; on Rule 29.15 appeal his counsel was ineffective and the conviction reversed, then retried and again convicted.
- At the second trial the State read Williams's first-trial testimony over objection; Williams also objected to references to an uncharged robbery.
- During both trials Williams claimed self-defense; the victim Clinton was killed and Johnson aided in the wheel theft scheme.
- Police recovered Williams's gun, Johnson’s statements, and wheel/tire evidence; Williams was arrested in his apartment after the Monte Carlo was found.
- The court affirmed the conviction, addressing two evidentiary issues on appeal: admission of first-trial testimony and uncharged-robbery references.
- Key standards include abuse of discretion for evidentiary rulings and de novo review for constitutional rights questions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of first-trial testimony at second trial | Williams contends the read testimony was compelled | State argues admissible as voluntary admission | Denied; not involuntary or effectively compelled |
| References to uncharged robbery evidence | Evidence shows Williams's propensity for crime | Evidence relevant to motive and sequence of events | Denied; evidence admissible to show motive and context |
Key Cases Cited
- Pelz v. State, 831 S.W.2d 635 (Mo. App. W.D.1992) (admission of prior voluntary testimony as admissions; not compelled testimony)
- Simmons v. United States, 390 U.S. 377 (U.S. Supreme Court 1968) (compulsion tension between rights; admissibility of testimony in later trial)
- Samuels v. State, 965 S.W.2d 913 (Mo. App. W.D.1998) (extension of Simmons to Sixth Amendment/counsel issues; compelled testimony analysis)
- Williams v. Williams, 134 S.W.3d 766 (Mo. App. W.D.2004) (background on indigence and state funds for experts (Williams I))
- Williams v. State, 254 S.W.3d 70 (Mo. App. W.D.2008) (Rule 29.15 ineffective assistance; later districts clarified prejudice)