Williams v. State
2017 Ark. 123
| Ark. | 2017Background
- In 2013 a jury convicted Antonio Williams of capital murder for the death of Kelvin Lott Shelton; Williams was sentenced to life without parole plus an 84‑month firearm enhancement. The conviction was affirmed on direct appeal.
- Williams filed a timely pro se Rule 37.1 petition alleging ineffective assistance of trial counsel; counsel later amended the petition and an evidentiary hearing was held.
- Williams raised two Strickland claims: (1) counsel failed to call alibi witness Daquasha Johnson; (2) counsel was ineffective for allowing introduction of a pretrial photo‑array identification (to explain an eyewitness’s in‑court ID).
- The trial court found Williams not credible on his claim that he had told counsel about Johnson; it credited counsel’s testimony that he investigated alibi witnesses and would have interviewed Johnson if alerted to her name. The court also found counsel made a reasonable strategic choice to introduce the photo‑array to explain the eyewitness’s in‑court identification.
- The court concluded Williams failed to prove deficient performance or prejudice under Strickland given offsetting evidence (statements by Williams and others, recorded jail calls, and other testimony) that undercut an alibi defense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether counsel was ineffective for allegedly failing to investigate and call alibi witness Daquasha Johnson | Williams: counsel did not sufficiently investigate; Johnson would have testified Williams was at home during the murder, creating reasonable doubt | State/Trial court: counsel investigated witnesses given; counsel would have contacted Johnson if told of her; other testimony showed both brothers were at house and Michael’s presence undermined using those alibi witnesses | Denied — trial court’s credibility findings supported; Williams failed to show deficiency or prejudice |
| Whether counsel was ineffective for permitting introduction of the photo‑array identification to counter an in‑court ID | Williams: once the photo‑array was suppressed, counsel should not have allowed its use; both IDs were unreliable; counsel should have obtained Williams’s express waiver | State/Trial court: counsel sought suppression, but when in‑court ID was not excluded counsel reasonably admitted the array to explain the in‑court ID; tactical decision within counsel’s judgment; Nixon does not require express consent to every tactical move | Denied — counsel’s decision was reasonable trial strategy; no deficient performance or prejudice |
| Whether Rule 37.1 is the proper vehicle to relitigate trial‑error claims about admissibility of evidence | Williams: challenges admissibility and identification reliability | State: claims of trial error are not cognizable in Rule 37.1; issue already decided on direct appeal (law‑of‑the‑case) | Denied — trial‑error admissibility claims not cognizable in Rule 37.1; law‑of‑the‑case bars relitigation |
| Whether Williams met Strickland’s prejudice prong considering totality of evidence | Williams: Johnson’s testimony would have raised reasonable doubt | State: record contains inculpatory statements, jail calls suggesting attempted witness tampering, and other evidence making a different outcome unlikely | Denied — no reasonable probability the result would have been different |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishing two‑prong ineffective‑assistance test)
- Florida v. Nixon, 543 U.S. 175 (counsel must consult client on important decisions but need not obtain express consent for every tactical choice)
- Rasul v. State, 458 S.W.3d 722 (Ark. 2015) (appellate standard and Strickland framework in Arkansas postconviction review)
- Hartman v. State, 508 S.W.3d 28 (Ark. 2017) (trial strategy/tactics fall within counsel’s professional judgment)