Williams v. State
323 Ga. App. 88
Ga. Ct. App.2013Background
- Williams appeals denial of motion for new trial following jury conviction for armed robbery and aggravated assault.
- Evidence viewed in light most favorable to guilty verdict; court does not weigh credibility; some competent evidence supports each element.
- Victim, Williams’ neighbor, identified Williams as assailant after incident at victim’s apartment; Williams demanded money and slashed victim with box cutter.
- Jury found Williams guilty; evidence from victim alone sufficient to sustain convictions.
- At sentencing, State introduced three Mitchell County guilty pleas for recidivist punishment; Williams challenges lack of advisement on post-conviction relief and ineffective representation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence for armed robbery and aggravated assault | Williams argues insufficiency of evidence. | State contends evidence supports each element beyond reasonable doubt. | Evidence sufficient; victim's testimony alone can sustain convictions. |
| Ineffective assistance of trial counsel claims | Williams alleges multiple deficient acts by trial counsel. | Appellate review shows no reversible errors; some claims abandoned or meritless. | Most claims meritless; partial abandonment; no prejudice shown substantial enough to reverse. |
| Recidivist-punishment proof and prior pleas | State failed to prove Williams knowingly and intelligently waived rights regarding prior pleas. | State offered documentary proof of counseled pleas; presumption of regularity applies. | State met initial burden; Williams failed to rebut presumption; no reversible error. |
| Ineffective assistance of first appellate counsel | Appellate counsel failed to pursue habeas relief and broader issues. | Counsel testified regarding timing and scope; no deficient performance shown. | No reasonable likelihood that different outcome; no ineffective assistance established. |
Key Cases Cited
- Goss v. State, 305 Ga. App. 497 (Ga. App. 2010) (standard of review on appeal from criminal conviction; evidence viewed for sufficiency)
- Vaughn v. State, 301 Ga. App. 391 (Ga. App. 2009) (sufficiency framework; credibility not weighed by appellate court)
- Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (establishes standard for confrontation of sufficiency of evidence)
- Matthews v. State, 284 Ga. 819 (Ga. 2009) (ineffective assistance standard; deficient performance plus prejudice)
- Robinson v. State, 277 Ga. 75 (Ga. 2003) (deference to trial court findings; independent legal review of facts)
- Dunlap v. State, 291 Ga. 51 (Ga. 2012) (transcription and related trial-issues rules; abandonment)