Williams v. State, 301 Ga. 712

Background

Defendant Joseph Scott Williams shot and killed Adiren Thompson during a June 2013 parking-lot confrontation; multiple witnesses and surveillance video showed Williams fired repeatedly, including shots to Thompson’s back, and no weapon was recovered from Thompson.
Williams claimed self-defense, alleging Thompson was the initial aggressor and had threatened/indicated possession of a gun; Williams admitted intentionally shooting but said he feared for his life.
Williams was indicted on multiple counts; convicted of malice murder and related offenses, sentenced to life without parole; appeals court reviewed several trial rulings and counsel-performance claims.
Key contested trial matters: denial of request to “shuffle” the jury pool; exclusion of certain prior-act evidence supporting self-defense; prosecutor’s cross-examination question about alleged third-party jury tampering; refusal to charge involuntary manslaughter; and ineffective-assistance claims based on alleged trial-counsel impairment and failure to present an enhanced video.
The court affirmed: no legal requirement to shuffle the jury; any evidentiary exclusion was harmless given overwhelming proof; curative instruction cured prejudice from the single question about tampering; involuntary manslaughter charge was unwarranted because shootings were intentional; and ineffective-assistance claim failed (no prejudice and trial-court credibility findings adverse to Williams).

Issues

Issue	Williams' Argument	State's Argument	Held
Jury pool shuffle	Court should have called jurors in a different order to improve representativeness/impartiality	No legal requirement to reorder jury list; court acted within discretion	Denied — no law requires shuffling; no abuse of discretion (Thomason cited)
Exclusion of prior-acts evidence (juvenile shooting)	Evidence of Thompson’s prior violent act was relevant to Williams’ state of mind for self-defense	Court properly excluded because context/similarity was insufficient; some other violent-acts evidence was admitted	Any exclusion harmless — overwhelming evidence of guilt made it highly probable exclusion didn’t affect verdict
Exclusion of evidence that Thompson first showed Williams how to use a gun	Shows prior difficulties and fear, supporting self-defense	Giving a gun without more isn’t a violent act or proof of hostility; not showing prior difficulty	Affirmed — evidence irrelevant to dispute and properly excluded
Prosecutor question about third‑party jury tampering	Question prejudicial; warranted mistrial	State had good-faith basis for asking; single question promptly addressed	Denied mistrial — court gave curative instruction; single question unlikely to have affected verdict
Jury charge on involuntary manslaughter	Charge warranted because death could result from non-felony unlawful act or recklessness	Evidence showed intentional shootings, not accidental or reckless discharge	Refused — involuntary manslaughter improper where defendant admitted intentional shooting
Ineffective assistance of counsel (impairment, failure to play enhanced video)	Counsel was impaired and failed to play enhanced video that would have supported self-defense	Trial court found no credible proof of impairment; enhanced video would not have changed outcome	Denied — no deficient performance shown; even if deficient, no reasonable probability of different result

Key Cases Cited

Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of the evidence)
Thomason v. State, 281 Ga. 429 (trial court discretion on jury pool manipulation)
Smith v. State, 299 Ga. 424 (harmless-error test under Evidence Code)
Robinson v. State, 277 Ga. 75 (admission of evidence and self-defense rejection where repeated shots to victim's back)
Parks v. State, 300 Ga. 303 (likelihood that evidentiary rulings affected verdict where physical evidence overwhelmingly showed guilt)
Turner v. State, 299 Ga. 720 (review of curative instruction vs. mistrial discretion)
Sanders v. State, 290 Ga. 445 (curative instruction sufficiency standard)
O’Neal v. State, 288 Ga. 219 (evaluating impact of omitted curative instruction given strong evidence)
Adams v. State, 260 Ga. 298 (improbability that prosecutor comment affected verdict)
State v. Springer, 297 Ga. 376 (definition of reckless conduct vs. intentional act)
Harris v. State, 272 Ga. 455 (involuntary manslaughter charge not warranted where defendant admitted intentional shooting)
Bennett v. State, 254 Ga. 162 (same principle regarding refusal to charge involuntary manslaughter)
Wright v. State, 296 Ga. 276 (ineffective-assistance framework and deference to trial-court credibility findings)
Jones v. State, 296 Ga. 561 (presumption of reasonable counsel performance)
Mohamud v. State, 297 Ga. 532 (admissibility limits for specific acts of violence)
Woods v. State, 275 Ga. 844 (prejudice requires showing that omitted evidence would have been relevant and favorable)