Williams v. State
290 Ga. 418
Ga.2012Background
- Appellant Bryant Williams was found guilty of malice murders of Linda Mathis and Marlow Mathis and sentenced to life without parole.
- Crimes occurred April 30, 2008; Williams argued with Linda, his girlfriend, and demanded she move out before he returned from work.
- He came home early, found the victims, shot Linda three times and Marlow, killing Linda, Marlow, and the fetus.
- Williams admitted to other witnesses and GBI agents that he shot the victims.
- A stipulated bench trial on February 8, 2011 found Williams guilty on all charges (except one feticide) with statutory aggravating circumstances for the malice murders; sentencing followed; a motion for new trial was denied; he appealed.
- The court affirmed the denial of Williams’ motion for new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to convict | Williams | Williams argues insufficient evidence | Evidence supports guilt beyond reasonable doubt |
| Admissibility of statements during custodial interrogation | Williams invoked right to silence ambiguously | Miranda rights not clearly invoked; interrogation permissible | Statements admitted; not an unequivocal invocation of the right to silence |
| Hearsay evidence under the necessity exception | Wynn statements were improperly admitted | Any error was harmless due to other admissible evidence | Harmless error; other evidence covered same subject matter |
| Chain of custody for bullets and casings | Chain of custody was defective | Chain established; items identified by multiple witnesses | Chain established with reasonable certainty; admissible |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (evidence legally sufficient for conviction when viewed in light most favorable to verdict)
- Tarver v. State, 278 Ga. 358 (Ga. 2004) (sufficiency for aggravating circumstances under OCGA § 17-10-30 (b))
- Perez v. State, 283 Ga. 196 (Ga. 2008) (equivocal/unambiguous invocation of right to silence in custodial interrogation)
- Weaver v. State, 288 Ga. 540 (Ga. 2011) (interpretation of statements as internal conflict, not clear invocation)
- Turner v. State, 287 Ga. 793 (Ga. 2010) (equivocal assertion of right when saying not to talk further)
- Gardner v. State, 273 Ga. 809 (Ga. 2001) (harmless error in evidentiary rulings when other evidence supports)
- Smith v. State, 266 Ga. 827 (Ga. 1996) (hearsay exception applicability; corroborating evidence sufficient)
- Kempson v. State, 278 Ga. 285 (Ga. 2004) (chain-of-custody sufficiency considerations)
- Baker v. State, 250 Ga. 671 (Ga. 1983) (evidence integrity; sufficiency of chain-of-custody)