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Williams v. State
61 So. 3d 981
| Miss. Ct. App. | 2011
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Background

  • 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)
Read the full case

Case Details

Case Name: Williams v. State
Court Name: Court of Appeals of Mississippi
Date Published: May 17, 2011
Citation: 61 So. 3d 981
Docket Number: No. 2010-KA-00803-COA
Court Abbreviation: Miss. Ct. App.