Williams v. State
309 Ga. App. 688
Ga. Ct. App.2011Background
- Williams was incarcerated in a Georgia county jail when he took two meals, prompting a dispute over jail policy limiting meals to one.
- Officer Holmes attempted to reclaim a tray; Williams refused and consumed from the second tray.
- A struggle ensued: Holmes knocked trays, Williams hit Holmes, and a hand-to-hand fight began with Holmes, Rivera, and other officers intervening.
- Rivera and Holmes sustained injuries; officers used a TASER to subdue Williams.
- This court previously affirmed Williams’s felony obstruction convictions but remanded to address ineffective-assistance claims; on remand, the trial court rejected those claims.
- The Court of Appeals affirmed, holding Williams failed to show deficient performance or prejudice under Strickland.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance for failure to offer force standards/policy | Williams | Williams cannot show prejudice | No ineffective assistance |
| Failure to request jury charges on force_reasonableness/malice | Williams | Charges not supported by evidence | Counsel not deficient; no impact on outcome |
| Failure to object to full code section charge | Williams | Applicable parts used; not prejudicial | No error; trial court limited to indictment elements |
| Failure to file in limine to restrict impeachment if Williams testified | Williams | Strategic choice disclosed to Williams | No reasonable probability of different outcome |
| Effect of Williams's testimony on outcome | Williams would testify consistent with facts | Undisputed facts already established | No prejudice; trial counsel not ineffective |
Key Cases Cited
- Suggs v. State, 272 Ga. 85 (2000) (adequacy of trial counsel's strategic decisions and standard of review for ineffective assistance)
- Bruce v. State, 252 Ga.App. 494 (2001) ( Strickland framework and prejudicial impact apply to ineffective assistance claims)
- Mahoney v. State, 296 Ga.App. 570 (2009) (nonlinear ordering of Strickland components permissible)
- Somchith v. State, 272 Ga. 261 (2000) (evidence-supported charges; impeachment considerations)
- Potts v. State, 207 Ga.App. 863 (1993) (affirmative acceptance of complete code charges when portions apply)
- Williams v. State, 301 Ga.App. 731 (2009) (prior remand; no unreasonable force shown under law)