Williams v. State
312 Ga. App. 693
Ga. Ct. App.2011Background
- Williams was convicted of trafficking in cocaine and violating the Georgia Controlled Substances Act after a confidential informant purchased a kilogram of cocaine from him following two failed attempts; audio recordings, video, and testimony from accomplices, the informant, and the agent in charge comprised the trial evidence.
- The court played audio and video recordings of the drug purchase; the informant and the officer testified about the purchase and operation.
- Williams sought a new trial arguing (1) improper and prejudicial hearsay about his prior drug activity, (2) improper character evidence, and (3) ineffective assistance for not excluding such evidence and for not impeaching the informant’s reliability.
- The trial court admitted the challenged testimony and evidence; the defense objected, and Williams moved for a mistrial which was denied.
- On appeal, the court reviews the claimed errors and ultimately affirms the judgment, finding any error harmless in light of the overwhelming proof of guilt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Hearsay about officer’s targeting Williams admissible? | Williams | State | Error to admit; harmless under total evidence. |
| Improper character evidence from informant’s goal? | Williams | State | Error to admit; harmless given overwhelming guilt. |
| Ineffective assistance for not renewing motion in limine and not impeaching reliability? | Williams | State | No reasonable probability of different outcome; claims fail. |
| Harmlessness framework applied to evidentiary errors? | Williams | State | Harmless given substantial corroborating evidence. |
| Did improper evidence require reversal under Strickland analysis? | Williams | State | No reversible prejudice; Strickland not satisfied. |
Key Cases Cited
- Teague v. State, 252 Ga. 534, 314 S.E.2d 910 (1984) (limits on when officer motive is explanatory in hearsay)
- Johnson v. State, 238 Ga. 59, 230 S.E.2d 869 (1976) (harmless error in light of overwhelming evidence)
- Palmer v. State, 186 Ga. App. 892, 369 S.E.2d 38 (1988) (harmless error standard for evidentiary issues)
- Lampley v. State, 284 Ga. 37, 663 S.E.2d 184 (2008) (Strickland prejudice assessment in ineffective assistance)
- Strickland v. Washington, 466 U.S. 668, 104 S. Ct. 2052, 80 L. Ed. 2d 674 (1984) (test for ineffective assistance of counsel)