Williams v. State, 280 Ga. 297

Summary

The Supreme Court of Georgia affirmed Johnny Mack Williams's convictions for felony murder, aggravated assault, and possession of a knife during the commission of a felony arising from a fatal stabbing. The court rejected challenges to the jury instructions and found the evidence sufficient under Jackson v. Virginia. It remanded the case for an evidentiary hearing on Williams's claim of ineffective assistance of trial counsel because the claim was raised at the earliest practicable moment.

Holdings

1. The evidence was sufficient to authorize a rational trier of fact to find Williams guilty beyond a reasonable doubt of felony murder, aggravated assault, and possession of a knife during the commission of a felony.
2. The record did not support Williams's contention that the trial court failed to charge that voluntary manslaughter was a lesser included offense of felony murder.
3. The trial court did not commit reversible error by including in its second voluntary-manslaughter instruction the language that a killing after an interval between provocation and killing may be considered revenge and punished as murder.
4. Remand was required for the trial court to conduct an evidentiary hearing on Williams's ineffective-assistance-of-trial-counsel claim.

Questions Presented

1. Whether the evidence was sufficient to support convictions for felony murder, aggravated assault, and possession of a knife during the commission of a felony.
2. Whether the trial court failed to instruct the jury that voluntary manslaughter was a lesser included offense of felony murder.
3. Whether the trial court committed reversible error by recharging the jury on voluntary manslaughter and including language concerning an interval between provocation and killing.
4. Whether Williams was entitled to a remand for an evidentiary hearing on his claim that trial counsel provided ineffective assistance.

Disposition

other