State ex rel. Williams v. State

Summary

The Louisiana Supreme Court denied supervisory relief in a post-conviction proceeding, holding that the relator failed to establish ineffective assistance of trial or appellate counsel under Strickland v. Washington. The court also rejected claims concerning the confrontation right and alleged hearsay, noting that the trial court excluded the challenged testimony and issued a curative instruction. The court concluded that the relator had fully litigated his state post-conviction claims and that the denial was final absent a narrow exception permitting a successive application.

Holdings

1. Williams failed to prove that trial counsel performed deficiently or that any alleged deficiency prejudiced the reliability or fairness of the trial.
2. Williams failed to establish ineffective assistance of appellate counsel based on counsel's failure to raise the asserted confrontation issue.
3. Williams failed to establish a Confrontation Clause violation or resulting prejudice because the trial court excluded the challenged hearsay reference and instructed the jury to disregard it.
4. After fully litigating his state post-conviction application, Williams exhausted his right to state collateral review unless he could satisfy a statutory exception authorizing a successive application.

Questions Presented

1. Whether trial counsel provided ineffective assistance by failing to obtain additional photographs or video of the crime scene or request that the jury view the scene.
2. Whether appellate counsel was ineffective for failing to raise the alleged confrontation-related issue on direct appeal.
3. Whether the admission of the detective's brief hearsay reference violated Williams's rights under the Confrontation Clause or deprived him of a fair trial.
4. Whether Williams remained entitled to further state collateral review after fully litigating his post-conviction application.

Disposition

writ_denied