State v. Williams
2012 Ohio 4179
Ohio Ct. App.2012Background
- Indictment: Williams charged with two murders, two aggravated robberies, two felonious assaults, each with firearm specifications, arising from the Jan. 23, 2009 murder/robbery of Demetrius Frazier in Dayton; co-defendants Pinson and Maxwell implicated.
- Pretrial motions included Crim.R. 15 deposition motion for Rodriguez Noel, denied for lack of shown unavailability.
- Williams, proceeding pro se on a dismissal-of-counsel motion, later elected to keep appointed counsel after a hearing.
- Trial spanned four days with about 21 witnesses; Pinson testified after pleading to lesser offenses in exchange for truthful testimony.
- State offered extensive exhibits (9-1-1 tapes, crime-scene/photos, DNA/ballistics, extensive cell-phone records) and testimony from officers, coroner, and forensics personnel.
- Verdict: Williams found guilty on all counts; sentencing: aggregate 26 years to life in prison; post-judgment appeals followed raising multiple trial-counsel and evidentiary issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance of counsel. | Williams claims trial counsel failed to conduct proper research and obtain Noel deposition. | Counsel’s conduct falls within trial strategy; no prejudice shown. | First assignment overruled; no prejudice shown. |
| Admission of gruesome photographs. | Photos were more prejudicial than probative and should have been excluded. | Photographs had probative value to illustrate injuries and corroborate testimony. | Second assignment overruled; no abuse of discretion. |
| Counsel’s investigation into complaints against counsel; overall performance. | Trial court failed to adequately investigate complaints; ineffective assistance. | Court conducted a hearing; no egregious ineffectiveness; Williams opted to continue with counsel. | Third assignment overruled. |
| Admission of cellphone-records documents and related orders (supplemental issue). | Inclusion of orders/entries with exhibits prejudiced trial by evidentiary bolstering. | Information already before jury; inclusion was cumulative; no prejudice. | Fifth/Sixth assignments overruled; plain-error not established. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes standard for ineffective assistance of counsel)
- Bradley v. State, 42 Ohio St.3d 136 (Ohio 1989) (prejudice component of ineffective-assistance standard)
- Conway v. State, 109 Ohio St.3d 412 (Ohio 2006) (trial-strategy and cross-examination decisions fall within professional judgment)
- Gumm v. State, 73 Ohio St.3d 413 (Ohio 1995) (cross-examination and trial strategy considerations in ineffectiveness claims)
- Carter v. State, 72 Ohio St.3d 545 (Ohio 1995) (limits on claims where decisions are trial-strategy based)
- Lang v. State, 129 Ohio St.3d 512 (Ohio 2011) (plain-error standard for evidentiary issues)