Williamson v. State
2013 Ark. 347
| Ark. | 2013Background
- Charles Williamson was convicted of first-degree murder and a firearm enhancement for killing his girlfriend, Jessica Noles; sentence: life plus 15 years. Crime occurred April 23, 2010, in Hot Springs, Arkansas. Williamson confessed and testified at trial.
- Williamson told police (and testified) that during an argument Noles threatened to leave with their infant; he retrieved a .38 Special revolver, placed it at her forehead, cocked the hammer, and pulled the trigger. The shot was fired at contact/near‑contact range.
- Officers recovered the revolver (four live rounds) and one spent .38 shell casing. Williamson was holding the infant and told a caller he didn’t mean to hurt her. He called his grandmother, who called 911.
- At the station Williamson was given a Miranda form, initialed and signed the waiver, and made a typed, signed confession describing shooting Noles; he claimed mental-health issues and that he “blacked out.”
- Williamson moved to suppress the statement arguing improper Miranda advisement and incapacity to waive; the circuit court denied suppression. He appealed, arguing (1) insufficient evidence of purposeful intent for first-degree murder and (2) erroneous denial of suppression.
Issues
| Issue | Williamson's Argument | State's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to prove purposeful intent for first-degree murder | No substantial evidence that Williamson acted with conscious objective to cause death; he “blacked out” and lacked control | Evidence (close-range shot to head, method of firing, confession) permits inference of purpose; jury may reject claimed blackout | Affirmed — substantial evidence supported purposeful intent and first-degree murder conviction |
| Voluntariness/knowing waiver of Miranda rights | Williamson (young, special‑education, reading difficulty, mental disorders) lacked capacity to knowingly waive; allegedly told he could go home if he confessed | Officers read rights aloud, had Williamson read/initial each right and sign waiver; no prolonged questioning; confession adopted and signed after being read aloud | Affirmed — court found waiver and statement voluntary and knowing; suppression denial not clearly erroneous |
| False-promise inducement of confession | Williamson later alleged Brasfield promised he could go home if he confessed | State: argument not preserved at suppression hearing or in motion to suppress | Not reviewed on appeal; forfeited for failure to raise below |
| Preservation / Rule 4-3(i) review | — | — | Record examined; no prejudicial error found |
Key Cases Cited
- Wyles v. State, 368 Ark. 646, 249 S.W.3d 782 (2007) (review of sufficiency; intent often inferred from circumstances)
- Dodson v. State, 341 Ark. 41, 14 S.W.3d 489 (2000) (review includes all supporting evidence admitted at trial)
- Thompson v. State, 338 Ark. 564, 999 S.W.2d 192 (1999) (close-range shooting establishes natural and probable consequence of death)
- Walker v. State, 324 Ark. 106, 918 S.W.2d 172 (1996) (close-range gunshot to head supports purposeful intent)
- Osburn v. State, 2009 Ark. 390, 326 S.W.3d 771 (2009) (standard for independent review of suppression ruling; factors for voluntariness)
- Conner v. State, 334 Ark. 457, 982 S.W.2d 655 (1998) (false promise by police can render confession involuntary)
- Tryon v. State, 371 Ark. 25, 263 S.W.3d 475 (2007) (arguments not raised at suppression hearing are not preserved for appeal)