State v. Williams, 303 Kan. 585

Background

Michael Williams shot and killed his housemate, Sean Putnam; Williams admitted burial and concealment; charged and convicted of first-degree premeditated murder and given a hard 25 sentence.
Williams' defense was that he shot Putnam in defense of another (Deborah Weiss), claiming Putnam was holding Weiss by the hair and threatening her.
Defense sought to admit testimony of two women who alleged Putnam committed sexual assaults (M.M. and C.D.) to prove Williams' state of mind and the reasonableness of his belief; the court excluded M.M.'s specific-acts testimony and C.D. did not testify because defense could not locate her at trial.
After trial Williams moved for a new trial claiming (1) erroneous exclusion of M.M.'s testimony, (2) Brady violation for nondisclosure of C.D.'s statements/whereabouts, (3) failure to give a heat-of-passion voluntary manslaughter instruction, (4) prosecutorial misconduct in closing, and (5) cumulative error; the district court denied relief and the Kansas Supreme Court affirmed.
Key contested legal points: relevance of prior-specific-bad-acts evidence to show defendant's state of mind, materiality under Brady, duty to instruct on inconsistent lesser-included offenses, and whether prosecutor’s rhetoric crossed into improper credibility attacks.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Williams)	Held
Admissibility of M.M.'s testimony about Putnam's alleged sexual assault	Evidence of victim's prior violent acts is irrelevant here because no proof Williams knew of them; exclusion proper	M.M.'s specific-act testimony was probative of Williams' state of mind and should have been admitted under Walters	Court: Exclusion affirmed — testimony not relevant because no evidence Williams knew of the prior act when he shot Putnam
Brady violation for nondisclosure of C.D.'s allegations and whereabouts	Any nondisclosure was inadvertent and, even if known, C.D.'s allegations were not material because no proof Williams knew them at time of killing	Failure to disclose prevented locating an exculpatory witness whose testimony would have supported defense theory	Court: No Brady violation — prosecution knew C.D.'s info but Williams failed to show materiality or reasonable probability of a different outcome
Failure to give heat-of-passion voluntary manslaughter instruction	Instruction was foreclosed by defendant's theory so omission was proper	Defendant entitled to inconsistent defenses; instruction should have been given	Court: Error to refuse instruction was acknowledged but harmless under the "skip rule" because jury convicted of higher offenses, so no reasonable possibility the error affected verdict
Prosecutorial misconduct in closing (calling defendant's account a "story," "painting," or urging jury not to "buy into" his testimony)	Prosecutor argued credibility and consistency with evidence; language was within permissible latitude	Such language euphemistically called Williams a liar and improperly attacked credibility	Court: No misconduct — context did not equate "story" with lying; urging jury to weigh evidence and not "buy into" testimony was permissible

Key Cases Cited

State v. Walters, 284 Kan. 1 (1999) (prior specific bad acts may be admissible to prove defendant's state of mind when defendant knew of them)
State v. Huddleston, 298 Kan. 941 (2014) (establishes relevance threshold—material and probative—when admitting evidence)
State v. Ward, 292 Kan. 541 (2011) (standard for abuse of discretion review of evidentiary rulings)
State v. Prine, 297 Kan. 460 (2013) (affirming judgment on correct result despite incomplete trial-court reasoning)
State v. Brown, 300 Kan. 542 (2014) (prosecutor's references to a defendant's testimony as a "story" can be error when context implies fabrication)
State v. Hayes, 299 Kan. 861 (2014) (limits and explains application of the "skip rule" for lesser-included offenses)
State v. Horn, 278 Kan. 24 (2004) (describes "skip rule" curing failure to instruct on still lesser included offenses)
Brady v. Maryland, 373 U.S. 83 (1963) (suppression of favorable evidence violates due process when material)
United States v. Bagley, 473 U.S. 667 (1985) (defines "reasonable probability" materiality standard for nondisclosure)