State v. WilliamsÂ
253 N.C. App. 606
N.C. Ct. App.2017Background
- Defendant Daryl Williams was arrested after officers found an AK-47 in the back seat of a Crown Victoria and a .380 pistol beside the rear passenger tire; defendant had the vehicle keys in his pocket and personal items were inside the car.
- Defendant claimed he lacked knowledge of the firearms; two defense witnesses testified others placed the guns there.
- The State introduced testimony about a July 12, 2013 prior encounter in which officers found a Glock 22 under the driver’s seat of a different vehicle occupied by defendant.
- The trial court admitted the prior-incident evidence under Rule 404(b) for limited purposes (initially familiarity/possession; later instructed as knowledge and opportunity).
- Defendant was convicted of possession of a firearm by a felon and later sought review, arguing the prior-incident evidence was improper character evidence and unduly prejudicial under Rules 404(b) and 403.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Williams) | Held |
|---|---|---|---|
| Admissibility under Rule 404(b): knowledge | Prior possession shows defendant’s tendency to know about firearms; relevant circumstantial proof of knowledge | Prior incident is impermissible character evidence; does not logically prove knowledge of guns found later | Admission as proof of knowledge was erroneous — prior incident relied on improper intermediate character inference |
| Admissibility under Rule 404(b): opportunity | Prior possession shows access to firearms, thus opportunity to possess those recovered | Prior incident does not show special access to these particular firearms and adds only an inferential link vulnerable to prejudice | Admission as proof of opportunity was an abuse of discretion; probative value substantially outweighed by unfair prejudice |
| Rule 403 balancing (prejudice vs. probative value) | Probative given disputed constructive possession and defendant’s claimed lack of knowledge | Prior-incident evidence was cumulative and highly prejudicial, likely prompting propensity inference | Trial court failed adequately to justify Rule 403 balance; error was prejudicial and warrants new trial |
| Preservation and standard of review | State: defense did not renew objection in jury’s presence, so review should be plain error | Defense: circumstances (court acknowledged exception) justify reviewing for prejudicial error on the merits | Court reviewed for prejudicial error (declining plain-error limitation) and found reversible error on admissibility grounds |
Key Cases Cited
- State v. Coffey, 326 N.C. 268 (admission of other-crimes evidence governed by inclusion rule subject to exclusion if only showing propensity)
- State v. Al-Bayyinah, 356 N.C. 150 (similarity and temporal proximity limit Rule 404(b) inclusion)
- State v. Ray, 364 N.C. 272 (objection during out-of-jury voir dire insufficient to preserve objection; must object when evidence offered to jury)
- State v. Snead, 368 N.C. 811 (reaffirming the requirement to renew objections in jury’s presence)
- State v. Hembree, 368 N.C. 2 (evidence of other offenses can mislead jury into convicting for uncharged conduct; reversible error when risk is distinct)
- State v. Weldon, 314 N.C. 401 (admissibility of prior similar occasions to prove guilty knowledge when appropriately linked)