Williams v. State, 2013 Miss. LEXIS 78

Williams was convicted of sexual battery of a thirteen-year-old girl and sentenced to 20 years MDOC custody.
He allegedly confessed to Officer Joel after being read Mirandized; his mother indicated Williams is mentally incompetent and should be in the room during questioning.
Doctors at the State Hospital found Williams had an IQ around 53 and functioned at a second/third‑grade level, with capacity to stand trial but uncertain capacity to waive rights at the time of confession.
The suppression hearing focused on whether Williams knowingly and intelligently waived rights; no formal Findings of Fact were entered, but the judge discussed the doctors’ conclusions.
The trial court denied suppression, the Court of Appeals affirmed, and the Mississippi Supreme Court reversed and remanded for a new suppression hearing and new trial due to incorrect standard used by the trial court.
The core holding is that the State bears the burden to prove beyond a reasonable doubt that a waiver was knowing and intelligent, and the trial court erred by placing the burden on Williams

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the suppression court applied the correct legal standard	Williams	State bore burden to prove knowing, intelligent waiver beyond reasonable doubt	Yes; incorrect standard used; remand for new suppression hearing
Whether Williams’s mental retardation precludes a knowing, intelligent waiver	Williams’s incapacity undermines waiver	Waiver considered under totality of circumstances; could be valid	Remanded; require new suppression hearing; standard applied to assess waiver
Whether the confession should have been suppressed given the evidence	Confession unreliable due to mental deficits	Evidence supported voluntariness and waiver	Confession admitted only if proper suppression was upheld; here reversal warranted
Whether the burden-shifting error requires suppression of the confession outright	Error requires suppression due to burden shift	Error in standard, but possible preservation of confession	Court remands for new suppression hearing; does not decide final admissibility
Whether the trial court’s findings were clearly erroneous under Neal/Jones standards	Findings supported by record	Findings misapplied law	Remand for proper application of law and re-evaluation

Neal v. State, 451 So.2d 743 (Miss. 1984) (burden on State to prove voluntary and knowing waiver beyond reasonable doubt)
Jones v. State, 841 So.2d 115 (Miss.2003) (waiver and voluntariness must be proven beyond a reasonable doubt)
Fare v. Michael C., 442 U.S. 707 (U.S. 1979) (Miranda waiver must be knowing and intelligent)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (establishes right to warnings and waiver standards)
Spring v. Colorado, 479 U.S. 564 (U.S. 1987) (waiver inquiry includes voluntariness and knowing standard; totality of circumstances)
Mettetal v. State, 602 So.2d 864 (Miss.1992) (confession voluntariness and waiver standards in Mississippi)
Duplantis v. State, 644 So.2d 1235 (Miss.1994) (confession admissibility requires correct legal standard)
Jordan v. State, 995 So.2d 94 (Miss.2008) (burden to prove knowing waiver)
Dover v. State, 227 So.2d 296 (Miss.1969) (mental deficiency impact on knowing waiver)
Harvey v. State, 207 So.2d 108 (Miss.1968) (confession suppression due to mental incapacity)