Williams, Alfred James
PD-0482-15
| Tex. App. | Jun 2, 2015Background
- Williams was convicted of murder in Abilene, Texas, with a 25-year sentence (Oct. 8, 2012).
- On direct appeal, Williams challenged (1) denial of a mistrial for repeated State name-calling after an in limine order, (2) a limiting self-defense instruction under Tex. Penal Code §9.31(b)(5)(A), and (3) a Brady violation claim.
- The Eleventh Court of Appeals affirmed the conviction in a memorandum opinion (Mar. 31, 2015).
- This petition for discretionary review seeks reversal and remand for a new trial based on trial-court error and misapplication of the self-defense statute.
- The State and defense presented arguments centered on propriety of jury argument, statutory interpretation of self-defense limitations, and Brady disclosure.
- The petition argues the errors collectively undermined trial integrity and fairness and warrants remand for new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mistrial denial for prosecutorialmisconduct | Williams argues the State twice and then thrice violated the limine order by calling him a murderer. | State argues the objections and curative instructions safeguarded trial fairness; no incurable prejudice. | denial not abused; misconduct curable; no reversal (harm not incurable) |
| Self-defense limitation instruction | Williams asserts the limiting instruction under §9.31(b)(5)(A) was improper given the evidence. | State contends instruction proper under case law; evidence supported limiting instruction. | instruction not reversible; no harm; preserved error but harmless |
| Brady violation | Williams contends untimely disclosures prejudiced defense by exposing rumors of a gun | State argues no Brady violation; information not material or prejudicial | no reversible Brady error; even if preserved, not prejudicial |
Key Cases Cited
- Almanza v. State, 686 S.W.2d 157 (Tex. Crim. App. 1985) (standard for Almanza harm review)
- Hawkins v. State, 135 S.W.3d 72 (Tex. Crim. App. 2004) (factors for evaluating improper jury argument harm)
- Janney v. State, 938 S.W.2d 770 (Tex. App.—Houston [14th Dist.] 1997) (curative power of instructions after limine violations)
- Mosley v. State, 983 S.W.2d 249 (Tex. Crim. App. 1998) (three-factor test for evaluating improper jury argument harm)
- Lee v. State, 259 S.W.3d 785 (Tex. App.—Houston [1st Dist.] 2007) (self-defense limitation statute interpretation)