Williams v. State
302 Ga. 474
| Ga. | 2017Background
- In October 2012 Temon Jarmell Williams was arrested after Shawn Doughty was found fatally stabbed and Doughty’s sister was also stabbed; witnesses identified Williams at the scene and officers observed a bloody T‑shirt and a knife in Williams’s home during a protective sweep.
- A search warrant was later obtained; the knife in the bedroom had Williams’s blood/DNA, and another bent knife outside had the victims’ blood/DNA. Williams had superficial cuts he said were from being stabbed by the sister; the ER physician testified the cuts appeared self‑inflicted.
- Williams testified he acted in self‑defense, that Shawn attacked him with two knives, and that one knife was thrust into him during the struggle; the jury rejected self‑defense and convicted him of malice murder, felony murder, multiple aggravated assaults, attempt to murder, and multiple counts of possession of a knife during the commission of a crime.
- Post‑trial, Williams raised: (1) insufficiency of the evidence; (2) improper admission of ER physician’s opinion (disclosure under OCGA §17‑16‑4(a)(4)); (3) unlawful warrantless search/protective sweep tainting the warrant; and (4) multiple ineffective‑assistance claims (failure to impeach a witness with an old conviction, failure to seek continuance or retain rebuttal expert, failure to cross‑examine nurse about custodial statements, failure to object to supposedly improper 404(b)/prejudicial evidence).
- The Georgia Supreme Court affirmed convictions but found a sentencing error: one aggravated‑assault conviction (Count 4) and a related knife count (Count 13) should have merged with the malice‑murder sentence, so the sentencing on those counts was vacated.
Issues
| Issue | Williams' Argument | State's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Evidence insufficient to prove malice murder beyond a reasonable doubt; self‑defense credible | Jury could credit witnesses, physical evidence, and Dr. Earnest’s opinion that wounds were self‑inflicted | Affirmed: evidence sufficient under Jackson v. Virginia to support convictions |
| ER physician opinion admissibility (OCGA §17‑16‑4(a)(4)) | State failed to reduce any oral portions of the exam report to writing and timely disclose them, preventing defense from obtaining a rebuttal expert | State produced written medical records and there was no evidence of an oral report that needed reduction to writing | No violation; admission of Dr. Earnest’s opinion was proper |
| Suppression / protective sweep → warrant | Officers’ protective sweep was unreasonable and used plain‑view observations to procure the warrant | Sweep was a cursory protective sweep justified by a recent stabbing, a standoff, injured parties, and concern about others in the house; items were in plain view | Sweep lawful; plain‑view observations valid to support warrant; evidence admitted |
| Ineffective assistance of counsel (multiple subclaims) | Counsel failed to impeach neighbor with old murder conviction, failed to seek continuance/interview/retain expert, inadequately cross‑examined nurse, failed to object to testimony/opening statements re: rape/HIV/behavior | Counsel made reasonable strategic choices; no prejudice shown; unsettled legal questions not deficient performance; statements/testimony were intrinsic or admissible and/or defense opened door | Claims denied: counsel not ineffective; no Strickland prejudice shown |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
- Maryland v. Buie, 494 U.S. 325 (protective sweep doctrine)
- Strickland v. Washington, 466 U.S. 668 (ineffective assistance standard)
- Heywood v. State, 292 Ga. 771 (no obligation to reduce to writing an oral report absent evidence of such a report)
- Lawler v. State, 276 Ga. 229 (application of protective sweep in Georgia)
- Brewner v. State, 302 Ga. 6 (intrinsic evidence and 404(b) principles)