State v. Williams
2017 Ohio 1096
Ohio Ct. App.2017Background
- In early morning Oct. 26, 2014, Danny L. Williams fired multiple shots into the master bedroom window of Robert Kennedy and Heather Dorsten’s home; both victims were in the bedroom.
- Officers identified Williams quickly; shell casings matched ammunition from a handgun found under Williams’ couch and gunshot residue (GSR) was found on his hands after a warranted search.
- Williams was indicted on two counts of felonious assault (with firearm specifications), one count of improperly discharging a firearm into a habitation (with specification), having weapons while under disability, and obstructing official business; he pleaded not guilty.
- At the close of the State’s case at a two-day jury trial, defense counsel requested a continuance to locate an unlisted alibi witness; the trial court denied the request and the trial proceeded.
- The jury convicted Williams on all counts; the court merged counts and imposed a 15-year cumulative prison sentence. Williams appealed, raising denial of continuance (due process) and insufficiency of evidence as to the mens rea "knowingly."
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court abused discretion by denying continuance after State rested | State: denial proper under Unger factors; defendant failed to timely file alibi notice and request would disrupt trial | Williams: needed time to locate and interview three witnesses, including an alibi witness, at close of State’s case | Denial not an abuse of discretion; continuance untimely, would inconvenience court/parties, and Crim.R.12.1 alibi notice not filed |
| Whether evidence was sufficient to prove Williams acted "knowingly" in felonious assault counts | State: circumstantial proof (knowledge of house layout, presence of victims, motive over $20, matching ammunition, GSR, post-shooting texts planning an alibi) supports knowing intent | Williams: challenged sufficiency to show he knowingly intended to cause or attempt serious physical harm to both victims | Evidence sufficient when viewed most favorably to prosecution; jurors could infer knowing intent from layout familiarity, timing, motive, physical evidence, and texts |
Key Cases Cited
- Unger v. State, 67 Ohio St.2d 65 (trial-court continuance decision reviewed for abuse of discretion)
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (abuse-of-discretion standard defined)
- Thompkins v. Ohio, 78 Ohio St.3d 380 (standard for sufficiency-of-evidence review)
- Jenks v. State, 61 Ohio St.3d 259 (same; appellate sufficiency standard)
- Garner v. State, 74 Ohio St.3d 49 (intent usually proved from surrounding facts and circumstances)