Williams v. State
302 Ga. 147
| Ga. | 2017Background
- Victim Finesse Dawson was found dead on December 5, 2012, with extensive bruising, torn hair, a broken finger, and evidence of strangulation; a metal rod was found near the bed.
- Derrick Williams, married to Dawson, had a documented history of domestic violence against Dawson and other partners; he had pleaded guilty to related charges and was on probation at the time.
- Williams made calls to police and others claiming he struck Dawson and suspected an overdose; he later fled and was arrested in Nevada.
- Medical examiner concluded cause of death was strangulation; toxicology showed Alprazolam, Cyclobenzaprine, and Methylone at low/therapeutic levels, and no signs of overdose.
- At trial Williams was convicted of malice murder and sentenced to life without parole; he appealed the denial of his motion for new trial, challenging: (1) exclusion of toxicology testimony, (2) admission of prior-bad-acts evidence, and (3) admission of a prosecutorial demonstration.
Issues
| Issue | Williams' Argument | State's Argument | Held |
|---|---|---|---|
| Exclusion of toxicology testimony | Evidence of drugs in Dawson’s blood was relevant to show drugs made her more susceptible to asphyxiation or otherwise explain cause; should have been admitted | Evidence was irrelevant or prejudicial; trial court properly excluded; record does not show proffer tied to alleged susceptibility to choking | Exclusion not reversible; Williams didn’t preserve the choking-susceptibility theory and cannot show plain error or prejudice |
| Admitting prior bad acts of two ex‑girlfriends | Evidence was more prejudicial than probative and not admissible for a permissible purpose | Prior acts showed motive, intent, absence of mistake; were admissible | Even if erroneous, admission was harmless given overwhelming evidence against Williams |
| Prosecutorial demonstration (attorney struck punching bag 100 times) | Demonstration was irrelevant, speculative, and unfairly prejudicial | Demonstration illustrated volume of blows; trial court within discretion | If error, it was harmless in light of extensive medical evidence and photographs |
| Impeachment/cumulative toxicology testimony (Methylone level) | Toxicologist should have been allowed to impeach ME’s statement about levels and Methylone | ME already testified that Methylone has no therapeutic level; toxicologist testimony would be cumulative | Excluding that testimony was harmless because it was cumulative |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (establishes sufficiency-of-the-evidence standard for criminal convictions)
- Walker v. State, 301 Ga. 482 (plain-error review and prejudice standard under new Evidence Code)
- Lupoe v. State, 300 Ga. 233 (requirement that proponent’s theory of relevance be apparent to the trial court)
- Smith v. State, 299 Ga. 424 (harmless-error analysis for evidentiary rulings under new Evidence Code)
- Hood v. State, 299 Ga. 95 (harmless admission of challenged evidence where other strong evidence existed)
- Wilson v. State, 301 Ga. 83 (plain-error framework under Evidence Code)
- Woods v. State, 275 Ga. 844 (no prejudice shown where proffered evidence itself was never introduced)
- Goodwin v. Cruz-Padillo, 265 Ga. 614 (no prejudice where appellant failed to make proffer of uncalled witnesses)
- Lance v. State, 275 Ga. 11 (harmless-error principles where cumulative proper evidence exists)