State v. Williams
106 So. 3d 1090
La. Ct. App.2012Background
- Defendant Michael Williams was indicted for second degree murder (La. R.S. 14:30.1) following a 2009 shooting in Jefferson Parish.
- A 2011 jury trial ended with a unanimous guilty verdict on July 28, 2011.
- The trial court sentenced Williams to life without parole, then post-verdict motions failed; appeal was granted.
- Evidence linked a Glock pistol and .40 caliber cartridge cases to the crime scene and to the weapon recovered near the scene.
- A key eyewitness (Michael Gordon) testified to defendant’s pursuit and the sequence leading to gunfire; defendant claimed innocence and disputed location.
- The court later addressed sentencing issues in light of Graham v. Florida and Miller v. Alabama, remanding for resentencing to permit parole eligibility.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to identify the shooter and prove second degree murder | State argues Gordon’s testimony and physical evidence suffice | Williams argues circumstantial evidence fails to prove he was the shooter | Sufficient evidence supports guilt beyond a reasonable doubt |
Key Cases Cited
- Jackson v. Virginia, 443 So.2d 307 (U.S. 1979) (standard for sufficiency of evidence (robust review of evidence))
- State v. Mussall, 523 So.2d 1305 (La. 1988) (one witness’ positive identification generally sufficient)
- State v. Draughn, 950 So.2d 583 (La. 2007) (identity and negating misidentification burdens on State)
- State v. Neal, 796 So.2d 649 (La. 2002) (negation of reasonable misidentification in identity cases)
- State v. Price, 792 So.2d 180 (La. App. 5 Cir. 2001) (circumstantial evidence framework; Jackson standard applied)
- State v. Lathers, 868 So.2d 881 (La. App. 5 Cir. 2004) (circumstantial evidence methodology in sufficiency review)
- State v. Martinez, 38 So.3d 926 (La. App. 5 Cir. 2010) (specific intent may be inferred from circumstances)
- Shaffer v. State, 77 So.3d 939 (La. 2011) (Graham framework applied to juvenile sentencing)
- Graham v. Florida, 560 U.S. 56 (2010) (juvenile life-without-parole restrictions require meaningful release opportunity)
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (requires parole eligibility consideration for juveniles in certain life sentences)