Williams v. State
298 Ga. 208
| Ga. | 2015Background
- One-year-old Jewell Williams died of cocaine poisoning after ingesting cocaine found in the home shared by appellant Anthony Williams and co-defendant Stephanie Stephens.
- Police found a crystal substance in the living room in front of the sofa; trace cocaine was detected in a vacuum bag. No drug paraphernalia or additional quantities of cocaine were found.
- Multiple witnesses testified they had purchased crack cocaine at the residence on numerous prior occasions; testimony described cocaine commonly hidden in the sofa or Stephens’s purse and children being present during transactions.
- Appellant was often described as acting as a lookout during past sales; there was no direct evidence he was inside when the child ingested the cocaine.
- Appellant was convicted by a jury of felony murder and related predicate felonies (including possession with intent to distribute) as a party to the crimes. Post-trial proceedings vacated some counts; appeal followed and the Georgia Supreme Court affirmed the remaining conviction and life sentence.
Issues
| Issue | Williams' Argument | State's Argument | Held |
|---|---|---|---|
| Admissibility of prior similar-transaction evidence | Notice was untimely and evidence impermissibly put character in issue | Trial court properly admitted similar transactions after hearing; relevance outweighed prejudice and limiting instructions were given | Waiver of notice objection; admission not an abuse of discretion |
| Sufficiency of evidence for possession with intent to distribute (predicate felony) | Only prior-sales testimony supported distribution; no direct evidence on the night in question | Joint-possession presumption for cohabitants plus similar-transaction and circumstantial evidence sufficed | Evidence sufficient under Jackson v. Virginia to support conviction |
| Felony-murder predicated on distribution: foreseeability/proximate causation | Possession with intent to distribute is not necessarily a felony that creates foreseeable risk of death | Cocaine stored within reach of small children creates foreseeable risk; expert testimony linked ingestion to death | Felony murder conviction valid; proximate causation adequately instructed |
| Jury instructions (definitions, limiting use of similar acts, mutually exclusive verdicts) | Trial court failed to define delivery/distribute and misstated limiting instruction; inconsistent negligent vs. intentional predicates required mutually exclusive verdict instruction | Instructions as a whole were adequate; no plain error; Jackson-based mutual-exclusivity requirement overruled | No plain error; no instructional reversal required |
| Ineffective assistance of counsel (failure to request involuntary manslaughter instruction; failure to object to untimely notice) | Counsel should have requested involuntary manslaughter or objected to untimely notice | Strategic choice not to request manslaughter instruction; counsel knew similar-transaction witnesses and objection unlikely to succeed | Performance was reasonable; no Strickland prejudice shown |
Key Cases Cited
- Reeves v. State, 294 Ga. 673 (2014) (standard for admitting similar transactions and weighing prejudice)
- Rivers v. State, 296 Ga. 396 (2015) (review of limiting instructions on similar-transaction evidence)
- Stacey v. State, 292 Ga. 838 (2013) (rebuttable presumption of joint possession for cohabitants)
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence review)
- Whiting v. State, 296 Ga. 429 (2015) (no separate proximate-causation instruction required for felony murder when instructions as a whole are adequate)
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective-assistance standard)
- McKibbins v. State, 293 Ga. 843 (2013) (trial courts not required to define every common word in jury charge)