United States v. Williams
2011 U.S. App. LEXIS 1194
| 4th Cir. | 2011Background
- Indictment charged Williams with conspiracy to possess with intent to distribute heroin (Sept.–Oct. 2007).
- Pretrial, government sought a stipulation on drug testing; Williams objected; defense counsel signed the stipulation over objection.
- Stipulation stated 98.61 grams of heroin and was read to the jury, signed by defense counsel Lora Collins.
- Jury heard government testimony about source, custody, weight, and Williams’ involvement; stipulation aided proof of weight and chain of custody.
- Jury convicted Williams; sentencing used 98.61 grams; court imposed 78-month term; Fourth Circuit vacated conviction for Sixth Amendment error.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Confrontation Clause violation from stipulation admission | Williams argues stipulation violated his Sixth Amendment right | Government contends waiver or strategy supports admissibility | Yes; district court erred admitting stipulation over objection |
| Whether the error was harmless and warranted a new trial | Stipulation prejudiced the verdict and was essential to guilt | Overwhelming independent evidence establishes guilt; harmless error | No; error not harmless beyond reasonable doubt; conviction vacated and remanded |
Key Cases Cited
- Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (Confrontation Clause requires cross-examination to test reliability)
- Van Arsdall v. Banks, 475 U.S. 673 (U.S. 1986) (Harmless-error inquiry factors for Confrontation Clause violations)
- Neder v. United States, 527 U.S. 1 (U.S. 1999) (Harmless-error review; key elements for conspiracy)
- Arizona v. Fulminante, 499 U.S. 279 (U.S. 1991) (Harmless-error standard in broader constitutional errors)
- Chapman v. California, 386 U.S. 18 (U.S. 1967) (Harmless-error standard for constitutional errors)
- Melendez-Diaz v. Massachusetts, 557 U.S. 305 (U.S. 2009) (Confrontation right applies to forensic证证)
- United States v. Plitman, 194 F.3d 59 (2d Cir. 1999) (Defense counsel may waive confrontation rights in trial strategy)
- Hawkins v. Hannigan, 185 F.3d 1146 (10th Cir. 1999) (Defendant's right may not be waived by counsel in some circuits)
- Gaudin v. United States, 515 U.S. 506 (U.S. 1995) (Jury determination of each element; confrontation implications)