Williams v. State
2016 Ark. App. 507
| Ark. Ct. App. | 2016Background
- Henry Williams was tried for first-degree battery for shooting Jacent Winston; possession-of-firearms charge was later nolle prossed.
- Winston testified Williams pointed a gun, shot him in the legs, and was identified in a photo lineup; Williams testified Winston produced a gun during an altercation and the gun discharged during a struggle.
- Police developed Williams as a suspect after Cassandra Thomas called to report Williams had assaulted her minutes and about a block from the shooting; her description matched Winston’s description of the shooter.
- Detective Jarrod McCauley testified at trial about Thomas’s report, including detailed allegations (choking, facial injuries, split lip); defense objected under Rules 404(b) and 403.
- A witness described the shooter as "looking like a gangster," prompting a mistrial motion that the court denied and instructed the jury to disregard.
- The trial court admitted the fact of Thomas’s report as basis for suspect development but allowed the detailed allegations; Williams was convicted and appealed.
Issues
| Issue | Williams' Argument | State's Argument | Held |
|---|---|---|---|
| Admissibility of out-of-court report by Thomas | Testimony about Thomas’s allegations was hearsay and inadmissible 404(b) evidence; prejudicial under Rule 403 | Testimony was not offered for truth but to show the basis for investigating Williams (how he was developed as a suspect) | Statements explaining why police investigated were admissible (not hearsay) but detailed allegations of abuse were unfairly prejudicial; admission of those details was an abuse of discretion |
| Whether detailed 404(b) material was relevant or overly prejudicial | Specifics (choking, injuries) had little probative value and served only to show bad character | Details were connected in time/place and aided identity/opportunity reasoning | Court: initial relevance for identity/opportunity justified admitting existence of the report, but the graphic specifics exceeded probative value and were substantially prejudicial, requiring reversal |
| Harmless error analysis | Error harmless because conviction supported by other evidence | State argued evidence supported guilt | Court: not harmless — case turned on victim vs. defendant credibility, so prejudicial detail could have influenced verdict; reversed and remanded |
| Denial of mistrial over "looked like a gangster" remark | Instruction to disregard insufficient; mistrial warranted | Court instruction cured the prejudice | Court declined to decide this issue on appeal because it is unlikely to recur on retrial |
Key Cases Cited
- Rounsaville v. State, 374 Ark. 356 (trial-court evidentiary rulings reviewed for abuse of discretion)
- Decay v. State, 2009 Ark. 566 (Rule 403 exclusion requires showing probative value is outweighed by unfair prejudice)
- Green v. State, 365 Ark. 478 (other-offense evidence not admissible merely to show bad character)
- Martin v. State, 316 Ark. 715 (out-of-court statements admissible to show basis of police action)
- Miller v. State, 2010 Ark. 1 (harmless-error doctrine where evidence of guilt is overwhelming)
- Barrett v. State, 354 Ark. 187 (same — harmless-error standard)
- Austin v. State, 2016 Ark. App. 194 (contrasting fact patterns where error was harmless because evidence was overwhelming)
- Purdie v. State, 2010 Ark. App. 658 (credibility disputes can render evidentiary error reversible)
- Brooks v. State, 2014 Ark. App. 84 (appellate court may decline to reach issues unlikely to recur on retrial)