State v. Williams, 2024 Ohio 337

Harold Williams III was convicted for the murder of Angelo Catala and the shooting of a convenience store clerk in two incidents occurring three days apart in October 2020.
The murder occurred after a car accident outside a pizzeria, where Williams shot Catala following an argument; evidence included surveillance footage.
Three days later, Williams shot a convenience store employee after brandishing a gun and threatening store clerks, an incident also caught on video.
Williams was tried for multiple counts, including murder, attempted murder, felonious assault, and weapons violations, and received a 27-years-to-life sentence.
He appealed, arguing errors including improper joinder of offenses, evidentiary rulings, evidentiary sufficiency, jury instructions, and trial management.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Joinder of Offenses	Joinder permitted; incidents are related or evidence is simple and direct.	Offenses unrelated, separate events; joinder prejudiced defense.	No demonstrated prejudice; joinder affirmed.
Hearsay/Confrontation	Officer’s recounting of victim statements was proper under exceptions; no violation.	Admission violated Confrontation Clause and hearsay rules.	No preserved specific objection; no plain error; affirmed.
Authenticity of Video	Surveillance video properly admitted as evidence.	Video not properly authenticated at trial.	No timely objection; defense used same videos; no error.
Self-Defense & Weight	State’s rebuttal evidence refutes self-defense; jury could disbelieve Williams.	Williams acted in self-defense; state failed to disprove it.	Jury's rejection not against manifest weight; conviction affirmed.
Other Acts Evidence	Cross-examined on store shooting after Williams “opened the door.”	Inadmissible character evidence; improper under 404(B).	Evidence admissible due to Williams’s own testimony; affirmed.
Jury Instructions / Mistrial	No prejudice from merged felony murder; no error in handling jail mention.	Lesser-included instructions and curative instruction were warranted.	Errors, if any, were harmless or invited; affirmed.

State v. Lott, 51 Ohio St.3d 160 (explains defendant’s burden in showing joinder prejudice and state's methods to rebut)
State v. Thompkins, 78 Ohio St.3d 380 (sets standard for review of weight of evidence)
Crawford v. Washington, 541 U.S. 36 (addresses the Confrontation Clause and testimonial hearsay)
Davis v. Washington, 547 U.S. 813 (defines ongoing emergency exception for Confrontation Clause)
Michigan v. Bryant, 562 U.S. 344 (expands on emergency exception to Confrontation Clause)