Williams v. State
2010 Miss. LEXIS 590
| Miss. | 2010Background
- Williams was convicted of murder in Lafayette County; the court denied an assisted-suicide instruction; evidence included a suicide pact, preparation for suicide, and conflicting autopsy opinions; witnesses included medical experts, investigators, and Bracey’s associates; Williams confessed to aspects of the death and provided statements suggesting Bracey stabbed herself; defense sought a lesser-nonincluded instruction on assisted suicide under Miss. Code Ann. § 97-3-49; the Court of Appeals affirmed, and the Supreme Court granted certiorari to address the instruction issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court erred by not giving an assisted-suicide instruction | Williams argues evidence supports assisted suicide | State contends no evidentiary basis for lesser offense | Reversed; error in denying instruction; remanded for new trial |
Key Cases Cited
- Griffin v. State, 533 So.2d 444 (Miss. 1988) (lesser-included offenses from same nucleus of operative facts)
- Moore v. State, 799 So.2d 89 (Miss. 2001) (framework for lesser-offense instructions; evidentiary basis required)
- Mease v. State, 539 So.2d 1324 (Miss. 1989) (instruction granted if any evidence supports lesser offense)
- Brooks v. State, 18 So.3d 833 (Miss. 2009) (disparity in punishment affects instruction; some evidence suffices)
- Anderson v. State, 571 So.2d 961 (Miss. 1990) (evidence viewed in light favorable to accused; hypothetical jury may find lesser offense)