Williams v. State
300 Ga. 218
Ga.2016Background
- Victim Jeanette Woodson was found fatally shot in the head (.25 caliber) on Nov. 20, 1992; evidence indicated she was standing, her pockets were turned out, and her wristwatch had been forcibly removed.
- DNA from sperm recovered from Woodson (mouth and vagina) was later entered into CODIS and matched Anthony Lashawn Williams; Williams voluntarily went to police, denied sex with Woodson, and left an interview abruptly.
- The State introduced three prior-acts (similar transaction) convictions involving Williams: (1) forced sexual intercourse at gunpoint of ex-girlfriend T.J. (Aug. 1992); (2) violent assault/threat with a gun against ex-girlfriend A.C. (Apr. 1998); and (3) Feb. 1993 shooting of W.A. with a .25-caliber handgun (bullets later matched as same make/model).
- Trial court admitted those similar-transaction proofs to show motive, malice, intent, and bent of mind; it found the probative value outweighed prejudice.
- Williams was tried in 2004, convicted of malice murder, sentenced to life, moved for a new trial (denied), and appealed, challenging admission of the similar-transaction evidence and portions of the prosecutor’s closing argument as improper comment on his silence.
Issues
| Issue | Williams' Argument | State's Argument | Held |
|---|---|---|---|
| Admissibility of similar-transaction evidence | Prior acts were insufficiently similar (different relationships, victims, no direct proof same gun for all); differences outweighed similarities | Prior acts involved use of handguns, targeting victims’ heads, sexual/violent overtones, close temporal proximity and thus showed motive, intent, and bent of mind | Affirmed — trial court did not abuse discretion; similarities justified admission for motive/intent/bent of mind |
| Sufficiency of evidence | (No enumeration of insufficiency on appeal) | Evidence (DNA match, circumstances, eyewitness/location, ballistics similarity) was sufficient to convict | Affirmed — record sufficient under Jackson v. Virginia to support conviction |
| Prosecutor’s closing comments on silence/failure to testify | Statements were improper comments on failure to testify and silence to police, warranting reversal | No contemporaneous objection at trial; issue waived; plain-error review not applied | Affirmed — claim waived for lack of objection; no relief granted |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (sufficiency-of-evidence standard for convictions)
- Williams v. State, 261 Ga. 640 (standards for admitting similar-transaction evidence)
- State v. Ashley, 299 Ga. 450 (focus on similarities, lesser similarity needed for motive/intent vs. identity)
- Dillard v. State, 297 Ga. 756 (deference to trial court on similar-transaction findings)
- McBee v. State, 228 Ga. App. 16 (liberal approach to similar-transaction evidence in sexual-assault context)
- Scott v. State, 290 Ga. 883 (failure to object at trial waives claim on appeal)
- Durham v. State, 292 Ga. 239 (limits of plain-error review at time of trial)
- Bharadia v. State, 297 Ga. 567 (description of CODIS and DNA database)