Williams v. State
72 So. 3d 721
Ala. Crim. App.2010Background
- Williams was convicted of felony murder and sentenced to life in prison, appellate review followed.
- On October 3, 2008, Cory Landrum was shot and killed in the Alabama Village neighborhood of Prichard; Parnell and C.D., a juvenile, admitted involvement and testified at trial.
- Parnell testified Williams sought to borrow a pistol days before the murder and planned to rob someone; on the day, Williams robbed Landrum and shot him after demanding money.
- Landrum handed over a five-dollar bill; Williams took Landrum’s cellular phone; Landrum crashed his vehicle and died from injuries.
- Parnell recovered the gun and implicated Williams; forensic testing linked the gun to the shooting; C.D. testified to Williams’s role, with some contradictions about the phone.
- Smalley testified Williams was in the area but did not identify him; the court analyzed corroboration under § 12-21-222 to determine sufficiency of accomplice testimony.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of corroboration under § 12-21-222 | Williams contends accomplice testimony lacks corroboration. | State contends nonaccomplice evidence corroborates the accomplices’ testimony. | Insufficient corroboration; acquittal affirmed. |
Key Cases Cited
- Ex parte McCullough, 21 So.3d 758 (Ala.2009) (corroboration standard for accomplice testimony)
- Ex parte Hardley, 766 So.2d 154 (Ala.1999) (test for sufficiency of corroboration)
- Andrews v. State, 370 So.2d 320 (Ala.Crim.App.1979) (corroboration framework cited)
- Miles v. State, 476 So.2d 1228 (Ala.Crim.App.1985) (corroboration may be circumstantial and minimally sufficient)
- Ware v. State, 409 So.2d 886 (Ala.Crim.App.1981) (corroboration need not directly connect but tend to connect)
- Ex parte Bullock, 770 So.2d 1062 (Ala.2000) (corroboration rule caveats)
- Ex parte Stewart, 900 So.2d 475 (Ala.2004) (caveats on corroboration rule)
- Ex parte Hunt, 744 So.2d 851 (Ala.1999) (corroboration independence requirement)
- Sorrell v. State, 249 Ala. 292, 31 So.2d 82 (1947) (corroboration must be independent and substantive)
- Mills v. State, 408 So.2d 187 (Ala.Crim.App.1981) (corroboration may be circumstantial)
- Ex parte Bell, 475 So.2d 609 (Ala.1985) (corroboration standards for accomplice testimony)