Williams v. State
2011 Miss. LEXIS 504
Miss.2011Background
- Williams convicted of shooting into a dwelling; ballistics tied shots to a gun he admitted owning and possessing during the shooting.
- Bullets and shell casings found at Wells home; Williams admitted ownership of the gun used.
- Defense theory: Tina Brown caused the shooting due to a love triangle; no witness subpoenaed for key testimony.
- Trial court denied continuance to secure Charlie Brown, Sr.; defense opened with mention of his expected testimony.
- Jury found Williams guilty; sentencing included a ten-year term with specific fines and post-release conditions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did defense fail to timely subpoena Charlie Brown? | Williams | Williams | Claim dismissed without prejudice |
| Did failure to file post-trial motions render counsel ineffective? | Williams | State | No reversible prejudice; record shows no probability of different outcome |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong ineffective-assistance standard)
- Holland v. State, 656 So. 2d 1192 (Miss. 1995) (failure to raise post-trial issues can bar appellate review)
- Johnson v. State, 876 So. 2d 387 (Miss. Ct. App. 2003) (distinguishes Holland in some contexts)
- Parker v. State, 30 So. 3d 1222 (Miss. 2010) (articulates application of Strickland to post-trial issues)
- Archer v. State, 986 So. 2d 951 (Miss. 2008) (cited for related ineffective-assistance authorities)
- Wilcher v. State, 863 So. 2d 776 (Miss. 2003) (additional Mississippi precedent on counsel performance)