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Williams v. State
292 Ga. 844
| Ga. | 2013
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Background

  • 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)
Read the full case

Case Details

Case Name: Williams v. State
Court Name: Supreme Court of Georgia
Date Published: Apr 29, 2013
Citation: 292 Ga. 844
Docket Number: S13A0292
Court Abbreviation: Ga.