Williams v. State
308 Ga. 532
Ga.2020Background
- Victim Cory Robinson was found dead in a Fulton County extended-stay hotel room on Jan. 31, 2015; cause of death was asphyxia due to strangulation with neck hemorrhage and abrasions. DNA from Williams and possibly another person was under Robinson’s fingernails.
- Richard Williams II and Robinson were in a sexual relationship and lived together at the hotel. Robinson’s body was clothed, wrapped in a blanket, and had plastic bags over head and feet.
- Williams was indicted and tried for murder (malice murder conviction), sentenced to life, and pursued a motion for new trial asserting ineffective assistance of counsel.
- At trial Williams did not testify; defense theory (pushed by counsel Morris Fair) blamed a third party (Kelvin Spencer). Williams later claimed counsel refused to pursue an alternative defense: accidental death during consensual erotic asphyxiation.
- At the motion hearing Williams testified he had engaged in erotic asphyxiation with Robinson and that Fair would not listen; Fair testified Williams admitted killing Robinson and never told him of an accidental erotic-asphyxiation theory. The trial court implicitly credited Fair and denied the ineffective-assistance claim.
- The Georgia Supreme Court affirmed, finding counsel had no duty to investigate an uncommunicated theory and that Williams failed to show deficient performance or prejudice.
Issues
| Issue | Williams' Argument | State/Fair's Argument | Held |
|---|---|---|---|
| Whether counsel was ineffective for failing to investigate/present a theory that Robinson died accidentally during consensual erotic asphyxiation | Fair failed to investigate or present expert/witness evidence and refused the theory due to discomfort/homophobia and disciplinary problems | Fair reasonably pursued a third‑party theory; Williams never told Fair about erotic asphyxiation, so no reason for independent investigation | Held: No. Court credited Fair’s account; counsel not deficient for failing to develop a defense the client did not disclose; claim denied |
| Whether the evidence was sufficient to sustain a conviction for malice murder | (Williams did not contest sufficiency) | State: forensic injuries, cause of death, DNA, and flight evidence supported malice murder | Held: Sufficient. Court independently reviewed and found evidence adequate under Jackson v. Virginia |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishes two‑part ineffective assistance standard: deficient performance and prejudice)
- Jackson v. Virginia, 443 U.S. 307 (sets standard for sufficiency of the evidence review)
- Parker v. State, 305 Ga. 136 (counsel not deficient for failing to discover information that defendant could have provided)
- Wiggins v. State, 280 Ga. 627 (trial counsel’s strategic choices may be reasonable when based on defendant’s representations)
- Miller v. State, 285 Ga. 285 (defines prejudice standard as reasonable probability undermining confidence in outcome)
- Jordan v. State, 305 Ga. 12 (appellate review defers to trial court’s factual/credibility findings on ineffective assistance when supported by evidence)