State v. Williams, 2016 Ohio 4550

On Oct. 19–20, 2012 Michael Payne was found strangled and wrapped in trash bags; investigation tied the body, unique silver/blue-tied trash bags, and other items to an apartment leased by Maxamillion J. Williams and to co-defendants.
Indictments charged Williams with two counts of aggravated murder (including felony-murder predicates of kidnapping and aggravated robbery), murder, aggravated robbery, kidnapping, and tampering with evidence; cases tried jointly with co-defendant Hawkins.
Key eyewitnesses (Amy Lambert — a cooperating codefendant — Dalton, Bagley, and David) testified Williams participated in luring Payne to the apartment, using force/weapon, kicking/assisting during the assault, procuring cleaning supplies, and instructing others to dispose of the body; physical evidence (ligature, HDMI cable, bloodstains, DNA) corroborated involvement.
Jury convicted Williams of aggravated murder (merged), kidnapping, aggravated robbery, and tampering with evidence; trial court sentenced him to life without parole plus concurrent terms on other counts.
Williams appealed, raising (1) error in aider-and-abettor jury instruction, (2) improper sentencing based on perceived lack of remorse, and (3) insufficient/manifest-weight challenges (including prejudice from shackling after a courtroom outburst).

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Aider-and-abettor jury instruction	Instruction correctly stated law and required aiding that actually "aided the primary offender."	Instruction improperly allowed conviction on mere presence.	Court: No abuse of discretion; instruction read as a whole required more than mere presence (presence must be intended to and actually aid).
2. Sentence (life without parole) based on lack of remorse	Court permissibly considered lack of genuine remorse among R.C. 2929.12 factors; judgment entry shows statutory considerations.	Sentence improperly based on perceived lack of remorse and failed to weigh statutory factors.	Court: Affirmed; record supports trial court’s considerations and sentence is not clearly and convincingly unsupported or contrary to law.
3. Sufficiency/manifest weight of evidence; shackling prejudice	State: eyewitness testimony + physical/DNA evidence sufficed; shackling was justified and not visible to jury.	Williams: key witnesses unreliable; evidence insufficient or against manifest weight; shackling prejudiced jury.	Court: Convictions supported by sufficient evidence and not against manifest weight; no prejudice shown from restraints.

State v. Arnett, 88 Ohio St.3d 208 (2000) (trial court must consider R.C. 2929.11/2929.12 factors and may consider other relevant factors)
State v. Jackson, 141 Ohio St.3d 171 (2014) (defendant has right to be free of visible physical restraints unless court reasonably imposes them for safety, escape prevention, or decorum)