Williams v. State
291 Ga. 501
| Ga. | 2012Background
- Appellant Jamaal Williams was indicted in Houston County with co-defendants for crimes related to the shooting death of Robert Daughtry, Jr.; Marshall and Daniels pled guilty and testified for the State.
- Jury convicted Williams of felony murder, kidnapping, and related offenses; Durham and Oree were also convicted of felony murder and other charges.
- This Court previously affirmed co-defendant Oree’s convictions in Oree v. State, 280 Ga. 588 (630 SE2d 390) (2006).
- Appellant challenges the sufficiency of the kidnapping asportation element serving as the predicate for his felony murder conviction and the admission of purported hearsay statements.
- The Court affirms Williams’s convictions on the challenged issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of asportation under Garza | Garza factor 1 not satisfied; movement is brief. | All Garza factors satisfied; movement substantial enough and distinct from accompanying offenses. | Asportation element supported; Garza factors satisfied. |
| Hearsay evidence and preservation | Trial failure to object precludes appellate review. | Even if objected, errors meritless; conspiracy shown and admissibility proper. | Plain error review not available; admissibility upheld under existing rules. |
Key Cases Cited
- Garza v. State, 284 Ga. 696 (2008) (Garza factors for asportation; four-factor test)
- Hammond v. State, 289 Ga. 142 (2011) (Garza not requiring all four factors to be met)
- Tate v. State, 287 Ga. 364 (2010) (illustrates movement magnitude threshold)
- Henderson v. State, 285 Ga. 240 (2009) (movement danger considerations for asportation)
- Jones v. State, 290 Ga. 670 (2012) (time and distance considered in Garza first factor)
- Oree v. State, 280 Ga. 588 (2006) (background on conspiracy and prior rulings)
- Hill v. State, 281 Ga. 795 (2007) (party liability and inference of criminal intent)
- Livingston v. State, 271 Ga. 714 (1999) (co-conspirator statements admissible before conspiracy proved)
- Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency standard for conviction review)
- Vega v. State, 285 Ga. 32 (2009) (credibility and sufficiency considerations in review)
- Brooks v. State, 281 Ga. 514 (2007) (plain error review limitations for evidentiary rulings)