Williams v. United States
2013 D.C. App. LEXIS 658
| D.C. | 2013Background
- Williams arrested two nights after the murders near Hicks’s car scene and dropped revolver; the gun could have been the murder weapon per forensic evidence.
- Government used Williams’s CVS-arrest gun possession to tie him to the murders; witness testimony and gun-exposure were central to the case.
- Williams was tried four times; acquittal on the gun possession charge occurred in federal court, but its relevance to the murder trial remained contested.
- Defense argued admission of acquittal evidence would permit a “fair and balanced” view of evidence; court declined to adopt a broad rule admitting acquittal.
- The trial included testimony about the revolver’s potential connection to the murder scene; later, issues arose about preservation of evidence (car/clothing) and about an unauthenticated exhibit during deliberations.
- The court ultimately remanded to resentence after vacating certain murder and firearm-conviction counts and affirmed the rest of the judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of prior acquittal evidence | Williams argues acquittal should be admitted | Court should follow discretion to exclude; acquittal not probative | Court did not abuse discretion; acquittal evidence properly excluded |
| Preservation of evidence and due process | Failure to preserve car/clothing violated Rule 16 and due process | Negligence, not bad faith; sanctions appropriate | No reversible error; denial of full dismissal was harmless |
| Unauthorized transcript exhibit during deliberations | Jurors received unredacted transcript; prejudicial | Curative instruction mitigated error | No substantial sway; mistrial not warranted; error treated as harmless |
| Murder and firearm-conviction merger | Convictions should stand | Some convictions merge with others | Vacate two murder counts and three PFCV counts; remand for re-sentencing; rest affirmed |
Key Cases Cited
- Kinney v. People, 187 P.3d 548 (Colo. 2008) (acquittal evidence appropriate in limited circumstances; discretion to admit for limiting purposes)
- Dowling v. United States, 493 U.S. 342 (U.S. 1990) (collateral estoppel does not bar admissibility if burden differs; acquittal may be used to correct misinference)
- Bailey v. United States, 319 F.3d 514 (D.C. Cir. 2003) (acquittal/admission decisions discussed under Rule 403 and hearsay concerns)
- De La Rosa v. United States, 171 F.3d 215 (5th Cir. 1999) (acquittal evidence often excluded; Rule 403 balancing)
- Vega v. United States, 676 F.3d 708 (8th Cir. 2012) (acquittal evidence not generally admissible; hearsay/public-record considerations)