State v. Williams
2017 Ohio 7898
| Ohio Ct. App. | 2017Background
- Darius A. Williams was indicted for multiple robberies, aggravated robberies, and two counts of having a weapon while under disability; several counts carried three-year firearm specifications. Two robbery counts were later dismissed.
- Crimes: armed robberies of two convenience stores on May 20–21, 2015; store employees identified Williams at trial and videos of the incidents were shown to the jury.
- Physical evidence: fingerprints from items at one store matched Williams.
- Trial outcome: jury convicted Williams of two aggravated robbery counts, two robbery counts, and corresponding firearm specifications; bench found him guilty on weapons-under-disability counts and associated specifications. Total sentence: 24 years in prison.
- Appeal arguments: Williams challenged (1) sufficiency of the evidence, (2) manifest weight of the evidence (reliability of eyewitness ID, tattoos issue), and (3) erroneous post-release control advice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for robbery convictions | State: eyewitness IDs, video, and fingerprints support convictions | Williams: IDs unreliable (witnesses failed to note tattoos on hands) | Convictions supported; evidence sufficient to convict |
| Manifest weight of the evidence for robberies | State: testimony, video, and physical evidence credible; jury entitled to weigh ID reliability | Williams: identifications were unreliable and jury lost its way | Not against manifest weight; jury credibility determinations upheld |
| Operability of the firearm (firearm specs & weapons-under-disability) | State: victim testimony and videos showing brandishing suffice to prove operability or that gun could be readily made operable | Williams: no gun recovered; insufficient proof the gun was operable | Sufficient circumstantial evidence of an operable or readily operable firearm; specifications upheld |
| Post-release control term correctness | State (conceded): trial court misstated mandatory post-release control term | Williams: trial court advised three years but statute required five years for these offenses | Remand for correction: convictions affirmed but trial court must impose correct post-release control term |
Key Cases Cited
- State v. Thompkins, 78 Ohio St.3d 380 (1997) (distinguishes sufficiency and manifest weight standards)
- State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for sufficiency review)
- Foster v. California, 394 U.S. 440 (1969) (reliability of eyewitness ID is for the jury)
- DeHass v. State, 10 Ohio St.2d 230 (1967) (credibility determinations are for the trier of fact)
- Seasons Coal Co. v. Cleveland, 10 Ohio St.3d 77 (1984) (deference to trial court's assessment of witness demeanor)
- State v. Treesh, 90 Ohio St.3d 460 (2001) (appellate review limits on sufficiency and weight)
- State v. Yarbrough, 95 Ohio St.3d 227 (2002) (evaluation of witness credibility not part of sufficiency review)
- State v. Humberto, 196 Ohio App.3d 230 (2011) (eyewitness ID can support conviction)