Williams v. State, 301 Ga. 829

Victim Decarla Lomax was bludgeoned to death; Williams convicted of malice murder and related counts after a jury trial; evidence showed a history of domestic violence and recent threats by Williams.
At trial a witness (James Ryan) testified that, following a 2008 attack on Lomax, she had requested dismissal of charges; defense elicited that statement on cross-examination.
The State introduced a certified copy of Williams’ first offender plea (2009) from the 2008 incident over Williams’ objection; Williams argued on appeal the plea was not a "conviction" and thus inadmissible.
The medical examiner testified about timing/positioning of wounds with opinions that defense says were not provided in writing pretrial; Williams claimed a discovery violation and later raised ineffective assistance for counsel’s response at trial.
The trial court relied on Williams’ first offender pleas to impose recidivist sentencing under OCGA §17-10-7(c); Williams challenged use of first offender pleas for recidivist enhancement.

Issue	Williams' Argument	State's Argument	Held
Sufficiency of evidence	(Not challenged on appeal)	Evidence supported convictions	Evidence was sufficient to sustain convictions under Jackson v. Virginia
Admissibility of first-offender plea at trial	Plea is not a conviction and thus inadmissible for impeachment	Plea admissible to impeach witness by contradiction where witness suggested charges were dismissed	Trial court did not abuse discretion; even if error, admission was harmless given cumulative, overwhelming evidence
Discovery violation (medical examiner opinions)	State failed to provide written report as required; entitlement to new trial	Any alleged violation should have been raised at trial; failure to object waives claim	Claim waived for failure to raise at trial; not reviewed for plain error
Ineffective assistance for counsel's inaction re: discovery	Counsel should have sought continuance, expert, or mistrial after surprise testimony	Counsel effectively cross-examined the ME; tactical responses were reasonable; no prejudice shown	No ineffective assistance: performance reasonable and no prejudice proved
Use of first-offender pleas for recidivist sentencing	First-offender pleas are not convictions and cannot be used to enhance sentence	Trial court treated pleas as convictions for recidivist mandate	Sentencing as recidivist reversed; sentence vacated and case remanded for resentencing without relying on first-offender pleas

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency review)
Davis v. State, 269 Ga. 276 (1998) (first-offender plea not a conviction; limited admissibility)
Davis v. State, 273 Ga. 14 (2000) (remedy/resentencing when first-offender used improperly for recidivist sentence)
Carruth v. State, 290 Ga. 342 (2012) (first-offender record admissible to impeach defendant who claimed innocence of underlying charges)
Scruggs v. State, 253 Ga. App. 136 (2001) (impeachment by disproving facts to which witness testified)
Harrington v. Richter, 562 U.S. 86 (2011) (deference to counsel performance; strong presumption of reasonable assistance)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective assistance test)
Brown v. State, 288 Ga. 902 (2011) (tactical decisions not constitutionally deficient unless patently unreasonable)