Williams v. State
292 Ga. 844
| Ga. | 2013Background
- Williams was convicted in Chatham County of malice murder and related firearm offenses for the November 27, 2009 killing of Aljenje Flannings.
- On appeal, Williams challenges the trial court’s limitation on cross-examining a prosecution witness (Cheru) about another case in which Cheru was charged, later pled to a lesser offense.
- Williams also claims ineffective assistance of counsel based on numerous trial decisions and strategy choices.
- The appellate court reviews evidence for sufficiency under Jackson v. Virginia and analyzes cross-examination limits as a confrontation-right issue.
- The court ultimately affirms the convictions and denial of a new trial, finding no reversible error or prejudicial ineffective assistance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Cross-examination restriction on Cheru | Cheru’s potential punishment for armed robbery should be explored. | No pending charges or deals; cross-exam limit proper. | No abuse of discretion; limited cross-examination permitted given lack of pending charges or deals. |
| Ineffective assistance claims | Counsel performed deficiently in several respects across trial. | Counsel’s strategic decisions were reasonable under the circumstances. | Williams failed to show deficient performance or prejudice; claims fail under Strickland. |
| Sufficiency of the evidence | Evidence supports guilt beyond a reasonable doubt. | Challenge to sufficiency is not raised beyond standard cross-examination issues. | Evidence was sufficient to support a rational juror’s conviction. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court, 1979) (sufficiency standard for criminal convictions)
- Milinavicius v. State, 290 Ga. 374 (Ga. 2012) (impeachment and standard of review for evidence)
- Manley v. State, 287 Ga. 338 (Ga. 2010) (requirements for cross-examination to show bias and motive)
- Sapp v. State, 263 Ga. App. 122 (Ga. App. 2003) (limitations on cross-examination and impeachment strategy)
