Williams v. State
157 A.3d 398
Md. Ct. Spec. App.2017Background
- Williams and his girlfriend Angela Swan argued after he discovered her texts and a nude photo; Swan alleged he assaulted her, held a gun to her head, and pushed her down stairs; Williams denied assault and gun ownership, admitting only he tried to push her out and grab a towel.
- Swan reported the incident to police; officers observed her upset and later showed her how to remove nude photos posted to Facebook; Williams was charged with multiple offenses and convicted only of second-degree assault; other counts were dismissed or resulted in acquittal.
- At trial Williams presented three character witnesses who testified to his peaceful reputation; the State was allowed, over defense objection, to ask the witnesses whether they knew of Williams’s 1990 battery conviction and whether that knowledge would change their opinion.
- Each witness answered they were not aware of the 1990 conviction and that knowledge would not change their opinion; the jury convicted on second-degree assault and the court sentenced Williams to six months incarceration (with most time suspended) and probation.
- Williams appealed challenging (1) admission of the 1990 battery conviction on cross-examination of character witnesses as too remote and unfairly prejudicial, and (2) the trial court’s refusal to reinstruct the jury on the defense of property when they asked for the definition of second-degree assault.
- The Court of Special Appeals affirmed, holding the trial court did not abuse its discretion on either ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of 1990 battery conviction to impeach character witnesses | The 1990 conviction is too remote and its probative value is substantially outweighed by unfair prejudice | The State argued the conviction is relevant to rebut testimony that Williams is peaceful and to test the witnesses’ basis for opinion; they opened the door by eliciting reputation evidence | Court: admission was within trial court discretion; conviction was relevant to impeach reputation and not unfairly prejudicial |
| Jury reinstruction on defense of property during deliberations | Reinstruction was necessary to avoid incomplete guidance and to protect Williams’s defense | Court and State: jury only asked for definition of second-degree assault; reinstructing on defense of property would unduly emphasize an unasked-for issue | Court: no abuse of discretion in refusing to highlight defense of property; jury’s question did not require supplemental instruction on that defense |
Key Cases Cited
- Michelson v. United States, 335 U.S. 469 (1948) (defendant who offers character evidence opens the door to inquiry into contrary matters)
- Watson v. State, 321 Md. 47 (1990) (prior conviction admissible only if relevant to character trait at issue; trial judge should assess relevance and remoteness)
- Ricketts v. State, 291 Md. 701 (1981) (limits on use of prior convictions to impeach defendant's credibility)
- Jackson v. State, 340 Md. 705 (1995) (unfair to let defendant present wholly favorable character evidence while precluding State from impeaching with a contradictory prior conviction)
- United States v. Edwards, 549 F.2d 362 (5th Cir. 1977) (trial court discretion to admit convictions older than ten years when used to impeach character testimony)
- United States v. Booz, 451 F.2d 719 (3d Cir. 1971) (upholding cross-examination about convictions over a decade old where relevant to credibility)