Williams v. State, 313 Ga. 443

Victim Betty Ranow was found dead in the Lawrenceville home she shared with Allen Williams on the morning of Dec. 19, 2010; Williams was indicted and convicted of felony murder (based on aggravated battery) and sentenced to life.
Ranow was last seen alive after 8:53 p.m. wearing a clean yellow coat; the same yellow coat was later recovered bloodstained from a trash can outside the house, and Williams told officers where the trash can was.
Autopsy: blunt-force trauma to head/neck/chest, multiple external and internal injuries (including broken ribs and footwear tread marks); manner homicide; DNA from Ranow matched Williams.
Williams called 911 early morning, claimed someone else had drugged and beaten Ranow and had given her the yellow coat; police found most blood inside the house and no signs of an outside assault.
State introduced two prior-acts: June 2010 incident where Williams struck Ranow, and an August 2010 beating of Ronald Strode (Strode identified Williams; Williams made statements to investigators about the Strode incident).
Trial court admitted the Strode evidence under OCGA §24-4-404(b) for identity; Williams also argued the court should have held a Jackson–Denno hearing on voluntariness of his statements. The Georgia Supreme Court affirmed, holding any admission error harmless.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Williams)	Held
Admissibility of Strode incident under OCGA §24-4-404(b) (identity)	The prior act is relevant to identity: similar use of hands, same house/people, close in time; sufficiently probative.	The Strode incident lacks a unique "signature" — dissimilar motive and circumstances — so 404(b) identity use is improper and unduly prejudicial.	The Court assumed possible error but ruled any admission was harmless given overwhelming other evidence of guilt; conviction affirmed.
Failure to hold Jackson–Denno hearing on voluntariness of Williams’s statements about the Strode incident	Either no reversible error or, if error, it did not contribute to verdict.	The court should have conducted a voluntariness hearing before admitting Williams’s custodial statements.	Court assumed error could have occurred but held any constitutional error harmless beyond a reasonable doubt; conviction affirmed.

Strong v. State, 309 Ga. 295 (2020) (sets Rule 404(b) admissibility framework)
Moon v. State, 312 Ga. 31 (2021) (identity evidence requires particularly stringent analysis)
Brooks v. State, 298 Ga. 722 (2016) (identity proof requires a unique modus operandi/signature)
Troy v. State, 312 Ga. 860 (2021) (evidentiary error reversible only if it harmed substantial rights)
Davenport v. State, 309 Ga. 385 (2020) (nonconstitutional error harmless if highly probable it did not contribute to verdict)
Jackson v. Denno, 378 U.S. 368 (1964) (due-process right to a fair hearing on voluntariness of confessions)
Virger v. State, 305 Ga. 281 (2019) (404(b) evidence cumulative of other evidence is harmless)
Howell v. State, 307 Ga. 865 (2020) (jurors presumed to follow limiting instructions; erroneous 404(b) admission can be harmless)