Wenzel Williams v. State of Indiana
2015 Ind. LEXIS 884
| Ind. | 2015Background
- Williams was charged in Madison County with two B-felony counts of dealing in cocaine based on two controlled-buy transactions.
- A confidential informant conducted two hand-to-hand exchanges under surveillance and recordings; the CI delivered crack cocaine to officers after each buy.
- Detective Gaskill testified that, in his experience, there was zero doubt that a drug transaction occurred, asserting it was a transaction for cocaine.
- The Court of Appeals affirmed Williams’s conviction; Indiana Supreme Court granted transfer to review Rule 704(b) disposition and harmlessness of the error.
- The Supreme Court held Detective Gaskill’s statement violated Rule 704(b) by expressing guilt, but found the error harmless given overwhelming independent evidence.
- Evidence included audio/video of both buys, CI testimony, and detective testimony corroborating the hand-to-hand exchanges and drug amounts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Gaskill’s statement violate Rule 704(b)? | State argues it did not fully determine guilt, only implied it. | Williams contends it is an improper ultimate-guilt declaration. | Yes; it violated 704(b) by declaring guilt. |
| Was the error harmless beyond a reasonable doubt? | State asserts overwhelming independent evidence supports guilt. | Williams contends the error could have swayed the verdict. | Yes; the error was harmless and convictions affirmed. |
Key Cases Cited
- Blount v. State, 22 N.E.3d 559 (Ind. 2014) (harmless error when independent evidence supports guilt)
- Steinberg v. State, 941 N.E.2d 515 (Ind. Ct. App. 2011) (opinion may lead to inference of guilt but must not state guilt)
- Robles v. State, 705 N.E.2d 183 (Ind. Ct. App. 1998) (death with intoxication opinion may imply guilt but not fully resolve charge)
- Goodson v. State, 747 N.E.2d 1181 (Ind. Ct. App. 2001) (identity or intoxication may imply guilt but not resolve charge)
- Smith v. State, 721 N.E.2d 213 (Ind. 1999) (avoidance of ultimate guilt conclusions in officer testimony)
- Wilkes v. State, 917 N.E.2d 675 (Ind. 2009) (recognizes ultimate-issue concerns in testimony)
- Lampkins v. State, 778 N.E.2d 1248 (Ind. 2002) (example of inadmissible ultimate-issue statements)
- Walker v. State, 988 N.E.2d 341 (Ind. Ct. App. 2013) (illustrates limits on inference from testimony)
- Head v. State, 519 N.E.2d 151 (Ind. 1988) (discussion of ultimate issues and jury role)