Williams v. State
61 So. 3d 981
| Miss. Ct. App. | 2011Background
- Joseph Williams was convicted of aggravated assault in Montgomery County, Mississippi.
- On Oct. 31, 2008, Williams, Joe Bibbs, and Tyrone Forrest drank and rode around in Williams's truck before going to Earnest Curtis's house and then a local nightclub.
- Curtis testified he heard gunshots, saw Bibbs on the ground, and saw Williams with a handgun after returning to Curtis's house.
- Bibbs testified Williams approached from the driver’s side and fired 8–9 times at Bibbs, who survived.
- Williams aided Bibbs to Curtis’s car and then to the hospital; Bibbs later told hospital staff the truth about the shooting to police, leading to the investigation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Nicknamed identification and admissibility | Williams argues nickname Too Sweet inflamed jury. | Williams contends nickname lacks evidentiary value and is improper 404 evidence. | No plain error; issue procedurally barred. |
| Juror for-cause strike due to friendship | Williams asserts juror was friends with Curtis and biased. | Court should strike biased juror; no prejudice shown. | Court did not abuse discretion; juror seated. |
| Sufficiency of the evidence | State failed to prove purposeful/knowing actions due to possible blackout. | Evidence showed Williams’s awareness before/after shooting; race to evidence supports guilt. | Evidence was legally sufficient to sustain conviction. |
Key Cases Cited
- Willis v. State, 999 So.2d 411 (Miss.Ct.App.2008) (plain-error review for nickname usage denied (non-fundamental error))
- Owens v. State, 177 Miss. 488, 171 So. 345 (Miss. 1936) (juror-witness relationships reviewed for discretion and assurance of fairness)
- Parker v. State, 825 So.2d 59 (Miss.Ct.App.2002) (juror assurances considered deference-worthy)
- Reed v. State, 764 So.2d 496 (Miss.Ct.App.2000) (competency of jurors; no abuse of discretion without bias)
- Bush v. State, 895 So.2d 836 (Miss.2005) (standard for reviewing sufficiency of evidence)
