Williams v. State, 276 Ga. 384

Summary

The Supreme Court of Georgia affirmed Dewaine Williams's conviction and life sentence for felony murder committed during an armed robbery. The court held that the evidence supported the verdict, the trial court properly denied a mistrial based on a witness's emotional reaction, and the jury instructions correctly stated the law concerning conspiracy, parties to a crime, and felony murder. The court also rejected Williams's ineffective-assistance claim.

Holdings

1. The evidence was sufficient for a rational trier of fact to find Williams guilty of felony murder beyond a reasonable doubt.
2. The trial court did not abuse its discretion by denying the motion for mistrial.
3. The instruction that a killing by one conspirator in furtherance of a robbery is a probable consequence of the unlawful design was an accurate statement of Georgia law, did not invade the province of the jury, and did not shift the burden of proof.
4. The State was not required to prove that Williams knew beforehand that his accomplice intended to use a gun.
5. Williams failed to establish ineffective assistance of counsel because he showed neither deficient performance nor prejudice.

Questions Presented

1. Whether the evidence was sufficient to support Williams's felony-murder conviction.
2. Whether the trial court abused its discretion by denying a mistrial after the victim's roommate became emotional upon viewing a photograph of the victim's body.
3. Whether the jury instruction that a killing by one conspirator in furtherance of a robbery is a probable consequence of the unlawful design improperly invaded the jury's province or shifted the burden of proof.
4. Whether Williams was entitled to a jury instruction requiring the State to prove that he knew his accomplice would use a weapon.
5. Whether trial counsel was ineffective for failing to object to the refusal of the requested lack-of-knowledge instruction.

Disposition

affirmed