Williams v. State
2011 Ark. 432
| Ark. | 2011Background
- Appellant Roderick Williams was convicted by a Desha County Circuit Court jury of capital murder, first-degree domestic battering, endangering the welfare of a minor, and being a felon in possession of a firearm, and sentenced to life without parole plus 72 years.
- The victim Cobb (grandmother) was killed by a shotgun shot fired by Williams on a porch, within close range, during a confrontation involving Harris and her infant.
- Harris testified that Williams had previously been subject to an order of protection and that he forcibly removed her and the child, dragged Harris by the hair, beat her in a car, and left the child on the roadside for a period.
- Three unspent shotgun shells were found on the porch near Cobb’s body, and autopsy showed a close-range shotgun wound with pellets and a shot cup.
- On remand after Williams v. State, the State and defense agreed to an order restricting use of the word ‘trial,’ but Harris later referenced ‘the last trial’ during testimony, leading to a mistrial motion that the circuit court denied.
- Appellate review focused on whether the evidence was sufficient to support capital murder with premeditation and deliberation, and whether the child-endangerment conviction and mistrial ruling were proper.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for capital murder | Williams argues no premeditation/deliberation shown. | State contends evidence supports premeditation from circumstances and conduct. | Substantial evidence supports premeditated murder. |
| Sufficiency of evidence for first-degree child endangerment | Evidence shows child not harmed; challenged as insufficient. | Evidence shows conduct created substantial risk to the minor. | Substantial evidence supports child-endangerment conviction. |
| denial of mistrial due to reference to a prior trial | Harris’s remark about a previous trial tainted the jury; mistrial warranted. | Less drastic admonition suffices; no mistrial required. | Circuit court did not abuse discretion; no mistrial required; admonishment appropriate. |
Key Cases Cited
- Evans v. State, 378 S.W.3d 82 (Ark. 2011) (premeditation may be inferred from circumstances)
- Carmichael v. State, 12 S.W.3d 225 (Ark. 2000) (premeditation may be formed instantaneously)
- Pearcy v. State, 375 S.W.3d 622 (Ark. 2010) (premeditation inferred from circumstances; weapon and wounds)
- Robinson v. State, 214 S.W.3d 840 (Ark. 2005) (conduct and weapon used inform sedition of premeditation)
- Tryon v. State, 263 S.W.3d 475 (Ark. 2007) (credibility of witnesses is for the jury)
- Davenport v. State, 281 S.W.3d 268 (Ark. 2008) (appellate review of witness credibility is limited)
- Arnett v. State, 122 S.W.3d 484 (Ark. 2003) (directed-verdict standard for sufficiency review)
- Kimble v. State, 959 S.W.2d 43 (Ark. 1998) (mistrial and admonition considerations when prejudicial testimony occurs)
- Morgan v. State, 308 S.W.3d 147 (Ark. 2009) (directed-verdict analysis and sufficiency review guidance)