164 So. 3d 1078
Miss. Ct. App.2015Background
- Twonia Williams shot and killed Katrina Sargent on December 4, 2009; Williams was indicted for deliberate-design murder and convicted by a Harrison County jury.
- Williams and the victim’s boyfriend, Sean Lindsay, had a prior relationship; Williams had recently discovered Lindsay was seeing Sargent.
- On the night of the shooting Williams drove to Sargent’s house, arrived with a loaded gun, and after an exchange in which Sargent said she would call police Williams pointed the gun and shot Sargent in the face/head.
- Witnesses (including Sargent’s niece and a neighbor) testified Williams threatened to “blow up everybody,” arrived armed, and shot Sargent as she was walking back toward her house.
- Williams testified she acted in the heat of passion, denying premeditation and claiming the shooting occurred during a heated argument.
- The trial court instructed the jury on murder and heat-of-passion manslaughter; Williams was found guilty of deliberate-design murder and sentenced to life. An earlier conviction had been set aside and remanded for a new trial in Williams v. State, 111 So.3d 620.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence for deliberate-design murder | State: evidence shows Williams killed Sargent with deliberate design | Williams: claimed heat-of-passion, no premeditation | Affirmed: evidence sufficient to prove deliberate design |
| Weight of the evidence — motion for new trial | State: verdict supported by witnesses and circumstances | Williams: verdict against overwhelming weight; claimed passion killing | Affirmed: verdict not so contrary to weight to constitute injustice |
Key Cases Cited
- Bush v. State, 895 So. 2d 836 (Miss. 2005) (standard for reviewing sufficiency and weight-of-evidence claims)
- Brown v. State, 965 So. 2d 1023 (Miss. 2007) (deliberate-design murder may be formed moments before the killing; intent may be inferred from manner of weapon use)
- Williams v. State, 111 So. 3d 620 (Miss. 2013) (prior trial conviction set aside and case remanded for new trial)