Williams v. State, 386 S.W.3d 750

Williams appeals a circuit court ruling denying a Rule 29.15 motion without an evidentiary hearing.
Trial resulted in guilty verdicts on first-degree robbery, armed criminal action, and unlawful use of a weapon.
Williams argued trial counsel failed to call Ernest Basic at trial; appellate counsel failed to raise a sufficiency challenge to the weapon conviction.
The motion court denied an evidentiary hearing; the court affirmed the denial on the merits, finding no ineffective assistance.
The record showed Williams exhibited a firearm in an angry or threatening manner, supporting unlawful use of a weapon; no viable defense would arise from Basic’s testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for failing to call a witness	Williams	State? Williams asserts trial counsel should have called Basic	No prejudice; no viable defense from Basic’s testimony
Ineffective assistance for failing to challenge sufficiency of the weapon evidence on appeal	Williams	Appellate counsel did not err in not appealing sufficiency	No reasonable probability of different outcome on appeal

State v. Letica, 356 S.W.3d 157 (Mo. banc 2011) (standard for sufficiency review in criminal convictions)
State v. Belton, 153 S.W.3d 307 (Mo. banc 2005) (deference to jury verdict in sufficiency review)
State v. Miller, 372 S.W.3d 455 (Mo. banc 2012) (standard for sufficiency of evidence in criminal cases)
Johnson v. State, 333 S.W.3d 459 (Mo. banc 2011) (ineffective assistance standard; prejudice requires reasonable probability of different outcome)
Strickland v. Washington, 466 U.S. 668 (1984) (establishes performance and prejudice prongs for IACclaim)