Williams v. State, 303 Ga. 474

Michael Williams babysat two children (Nasir, 4; Joy, 3) and was alone with them when Nasir suffered severe head trauma on Jan. 25, 2012 and later died from blunt force head injuries.
Medical evidence: skull fracture, subdural/subarachnoid bleeding, and brain swelling; medical examiner concluded adult-inflicted blunt force trauma (pounding head) and ruled death homicide.
Williams gave a post-Miranda statement describing a brief fall onto a toy truck and noted Nasir had complained of head pain previously.
Witnesses reported Williams admitting he had “whooped” the child and that he didn’t mean for the child to die; the younger sister testified Williams struck Nasir with a belt and remote.
Williams was convicted by a jury of malice murder and related counts, sentenced to life, filed posttrial motions and appeals; the Georgia Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Trial court denied funds for a medical expert	Williams: court should have funded an expert to challenge State’s medical evidence	State: Williams’ motion lacked required detail about the expert’s proposed work and costs	Denial affirmed — trial court did not abuse discretion because motion lacked required specificity
Ineffective assistance for counsel’s failure to secure expert funding	Williams: counsel was deficient in not furnishing enough info to obtain funds, prejudicing trial outcome	State: even assuming deficiency, no prejudice because defense expert at new-trial hearing agreed blunt force trauma caused death	Claim denied — Williams failed to show a reasonable probability of a different outcome
Strike of juror for cause	Williams: trial court erred in striking juror number 10 (briefly alleged juror dislike of guns in brief)	State: record contains no support for Williams’ juror-69/10 assertions	Denied — claim unsupported by the record and without merit
Sufficiency of evidence for malice murder	Williams: (implicit) alternative explanation (short fall) could explain injuries	State: medical and witness evidence supported adult-inflicted blunt force trauma and admissions	Affirmed — evidence was sufficient for a rational jury to convict

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency of the evidence review)
Crawford v. State, 267 Ga. 881 (trial court discretion on expert funding)
Roseboro v. State, 258 Ga. 39 (requirements for indigent defendant’s motion seeking expert funds)
Strickland v. Washington, 466 U.S. 668 (two-prong test for ineffective assistance of counsel)
Wright v. State, 291 Ga. 869 (application of Strickland standard in Georgia)
White v. State, 293 Ga. 635 (prejudice analysis where expert testimony would not have changed outcome)
Maxwell v. State, 290 Ga. 574 (procedural rule: appellate claims must be supported by the record)
Malcolm v. State, 263 Ga. 369 (clarification on vacatur versus merger of felony murder counts)