Williams v. State.1
2014 Ark. App. 561
Ark. Ct. App.2014Background
- On October 19, 2012, five victims were robbed at gunpoint at an apartment complex in Little Rock; items stolen included wallets, keys, cell phones, and a debit card.
- Victims varied in their estimates of how many perpetrators were involved (three to five); one victim (Griggs) reported a gun held to her head and later told her mother the robber had facial scarring.
- Police tracked a stolen iPhone using Find My iPhone to a North Little Rock location where they observed a white Chevy Impala; officers saw Michael Williams exit a nearby store and open the Impala’s door.
- Williams was searched and found with a stolen phone, Griggs’s keys, her debit card, and a firearm; the tracked phone was recovered inside the store.
- Williams was tried for five counts of aggravated robbery and five counts of theft of property, each with firearm enhancements; at trial three victims positively identified Williams as the person who held the gun to Griggs’s head.
- Defense moved for a directed verdict at the close of the State’s case, arguing the identification evidence was insufficient because victims had not previously reported Williams’s facial scarring; the motion was denied and the jury convicted on all counts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence/identification | State: eyewitness identifications and physical evidence (recovered stolen items and firearm) identify Williams as perpetrator | Williams: victims failed to report his facial scarring to police, making identifications unreliable and insufficient | Court: denied directed verdict; convictions supported by substantial evidence—unequivocal in-court IDs sufficient |
Key Cases Cited
- Boyd v. State, 369 Ark. 259, 253 S.W.3d 456 (Ark. 2007) (directed-verdict/sufficiency-of-evidence standard)
- Ridling v. State, 360 Ark. 424, 203 S.W.3d 63 (Ark. 2005) (appellate court does not reweigh evidence or assess witness credibility)
- Phillips v. State, 344 Ark. 453, 40 S.W.3d 778 (Ark. 2001) (reliability of eyewitness ID is for the fact-finder absent constitutional challenge)
- Stipes v. State, 315 Ark. 719, 870 S.W.2d 388 (Ark. 1994) (unequivocal eyewitness identification can sustain a conviction)