United States v. Kenya Williams, 19-4720

Background

Kenya Preston Williams was convicted by a federal jury of conspiracy to commit Hobbs Act robbery, Hobbs Act robbery, brandishing a firearm during a crime of violence, and being a felon in possession; sentenced to 276 months.
Key evidence included an investigating officer’s identification of Williams from surveillance footage and various physical items collected at the scene.
Williams did not contemporaneously object at trial to the officer’s identification testimony or to the admission/disclosure of certain physical evidence; appellate review is therefore for plain error.
On appeal Williams argued: (1) the officer’s identification was unreliable and should have been excluded under Rule 403; (2) Brady violations for failure to investigate/produce fingerprint, DNA, cell-site/location data, and evidence about another suspect; (3) denial of compulsory process because the government did not call additional witnesses about the other suspect; (4) prejudicial pre‑indictment delay; and (5) the verdict was against the weight of the evidence.
The Fourth Circuit affirmed, finding no plain error and concluding that any withheld or uncollected evidence was not clearly exculpatory or material and other claims were speculative.

Issues

Issue	Plaintiff's Argument (Williams)	Defendant's Argument (Government)	Held
Admission of officer identification under Rule 403	Officer failed to meaningfully investigate another suspect; identification testimony unduly prejudicial	Testimony was relevant and probative; prejudicial only in the ordinary incriminating sense, not unfair under Rule 403	Affirms: no plain error; testimony admissible (not unfairly prejudicial)
Brady: failure to disclose/investigate evidence (fingerprints, DNA, cell data, other suspect info)	Government suppressed exculpatory evidence that could have impeached or exonerated Williams	Evidence not clearly exculpatory or material; any value speculative and unlikely to change result given other strong evidence	Affirms: no plain error; Brady materiality not shown
Sixth Amendment/compulsory process (failure to call additional witnesses)	Government’s failure to call witnesses about other suspect deprived Williams of favorable testimony	Proffered effect of those witnesses is speculative and not shown to be material or vital to defense	Affirms: no plain error; compulsory process claim fails (speculative)
Pre-indictment delay / due process	Two-year delay caused loss of evidence and impaired defense	Defendant shows no actual, substantial prejudice; delay attributable to D.C. prosecution and not to prosecutorial bad faith	Affirms: no plain error; prejudice speculative and government justification adequate
Verdict against weight of evidence / request for new trial	Jury verdict inconsistent with evidence; conviction against the clear weight	Defendant did not move for a new trial; only moved for acquittal, so claim not preserved; court cannot grant new trial sua sponte	Affirms: plain-error review; no relief because defendant failed to seek new trial

Key Cases Cited

Olano v. United States, 507 U.S. 725 (1993) (plain-error forfeiture standard)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecutorial duty to disclose exculpatory evidence)
United States v. Tillmon, 954 F.3d 628 (4th Cir. 2020) (unfair prejudice under Rule 403 explained)
United States v. Muslim, 944 F.3d 154 (4th Cir. 2019) (elements of plain error review)
Juniper v. Zook, 876 F.3d 551 (4th Cir. 2017) (Brady materiality and reasonable probability standard)
United States v. Uribe-Rios, 558 F.3d 347 (4th Cir. 2009) (two-pronged test for pre-indictment delay due-process claim)
United States v. Galecki, 932 F.3d 176 (4th Cir. 2019) (compulsory process materiality requirement)
Tibbs v. Florida, 457 U.S. 31 (1982) (distinguishing sufficiency from weight-of-evidence/new-trial claims)
United States v. Martinson, 419 F.3d 749 (4th Cir. 2005) (preservation requirements for new-trial claims)