Williams v. State
2013 Ohio 1040
Ohio Ct. App.2013Background
- Williams was convicted of aggravated robbery and appealed denial of suppression; the appellate court previously addressed eyewitness identification issues from State v. Williams; Williams filed for wrongful imprisonment classification after conviction was vacated on appeal; he moved for summary judgment with alibi affidavits claiming hospital visitation from 10:00 p.m. to 2:30 a.m.; the state argued actual innocence was not proven; the trial court granted summary judgment in Williams’s favor but the State appealed; the appellate court reversed, requiring a hearing due to conflicting alibi evidence and the insufficiency of relying on the conviction reversal alone.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether actual innocence is proven for wrongful imprisonment | Williams relied on reversal and alibi affidavit | Reversal alone does not prove innocence | No; need affirmative, de novo innocence showing |
| Does suppressed eyewitness identification alone prove innocence | Suppression undermines state’s evidence | Suppression is not dispositive of innocence | No; suppression not dispositive, but relevant to issues of fact |
| Do conflicting alibi statements create triable issues | Affidavit shows hospital timeline; police statement conflicts | Conflicting statements create factual questions | Yes; summary judgment improper without hearing |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (burden to show no genuine issue of material fact)
- Mitseff v. Wheeler, 38 Ohio St.3d 112 (Ohio 1988) (summary judgment standards in Ohio)
- Temple v. Wean United, Inc., 50 Ohio St.2d 317 (Ohio 1977) (summary judgment standards (Civ.R. 56))
- State v. French, 72 Ohio St.3d 446 (Ohio 1995) (in limine rulings are tentative, can be revisited)
- Saunders v. McFaul, 71 Ohio App.3d 46 (8th Dist.1990) (summary judgment standards; light most favorable to nonmovant)
- Temple v. Wean United, Inc., 50 Ohio St.2d 317 (Ohio 1977) (reiterated Civ.R. 56 standards)
- Walden v. State, 47 Ohio St.3d 47 (Ohio 1989) (actual innocence burden for wrongful imprisonment)