State v. Williams, 99 Ohio St. 3d 439

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Questions Presented

1. Whether Williams's pretrial confession was obtained in violation of the Fifth, Sixth, or Fourteenth Amendments or Miranda v. Arizona.
2. Whether the prosecution committed prejudicial misconduct during voir dire, opening statement, closing argument, and the penalty phase.
3. Whether the trial court improperly required Williams to choose between substitute counsel and preserving his speedy-trial date.
4. Whether the trial court should have held a competency hearing and whether counsel were ineffective for failing to seek one or obtain another psychological evaluation.
5. Whether the deputy coroner was qualified to testify regarding blood-spatter evidence and whether counsel were ineffective for failing to object.
6. Whether evidence that Williams had been arrested and held in jail violated the presumption of innocence or resulted from ineffective assistance.
7. Whether the indictment's use of 'and/or' concerning alternative predicate felonies and the absence of a unanimity instruction violated Williams's rights.
8. Whether counsel were ineffective during the mitigation phase by presenting the testimony of a psychologist.
9. Whether the penalty-phase instructions improperly omitted mercy and misstated the effect of equipoise between aggravating and mitigating factors.
10. Whether the judge's post-verdict communication with jurors constituted prejudicial ex parte contact.
11. Whether cumulative error required reversal.
12. Whether the reasonable-doubt instruction, residual-doubt ruling, proportionality review, or Ohio's death-penalty statutes were unconstitutional.

Holdings

1. A suspect's Fifth Amendment rights are personal and cannot be invoked by an attorney on the suspect's behalf when the suspect himself has not clearly invoked those rights. Williams's attorney could not invoke Williams's right to silence or counsel merely by asking police not to question him.
2. The Sixth Amendment right to counsel had not attached when Williams was questioned because formal charges had not yet been initiated.
3. A suspect must unambiguously request counsel before police are required to cease interrogation under Edwards v. Arizona. Williams's shouting of his attorney's name during a chaotic arrest and his later comment about police chasing the attorney away were not unequivocal requests for counsel.
4. Williams voluntarily waived his Miranda rights and voluntarily confessed; the trial court properly denied suppression. Any error in admitting the confession would also have been harmless beyond a reasonable doubt because of the independent evidence of guilt.
5. The challenged prosecutorial comments, including improper personal-opinion phrasing during closing argument, did not deprive Williams of a fair trial or warrant reversal because they were either nonprejudicial, supported by the evidence, or forfeited except for plain error.
6. The trial court acted within its discretion by explaining that appointment of new counsel would require a continuance and allowing Williams to choose between new counsel and proceeding with current counsel.
7. The record did not contain sufficient indicia of incompetence requiring a competency hearing, and counsel were not ineffective for failing to request one or another psychological evaluation.
8. The deputy coroner was qualified to testify about bloodstains and blood-spatter evidence because her forensic-pathology experience, autopsy experience, work with blood patterns, and teaching experience would aid the trier of fact.
9. Brief evidence that Williams had been arrested and held in jail, offered to explain his volunteered admissions, did not violate the presumption of innocence or constitute plain error.
10. The use of 'and/or' in the aggravated-murder indictment and the lack of a specific unanimity instruction did not prejudice Williams or violate due process because the jury separately found him guilty of rape, aggravated robbery, and aggravated burglary and separately found each felony-murder specification.
11. Counsel were not ineffective for presenting Dr. Layne's testimony during the penalty phase because the decision was a reasonable professional judgment and Williams failed to establish prejudice.
12. The trial court did not abuse its discretion by omitting the word 'mercy' from the penalty-phase instructions, and the equipoise instruction did not constitute plain error.
13. The unrecorded post-verdict communication between the judge and jurors did not warrant reversal because counsel knew of the proposed communication, Williams did not establish that it involved substantive matters or caused prejudice, and the jury had completed its official task.
14. The aggravating circumstances of murder during rape, aggravated robbery, and aggravated burglary outweighed the mitigating evidence beyond a reasonable doubt, and the death sentence was appropriate and proportionate.

Key quotations

Factual background

In the early morning of February 18, 1999, Robert Williams entered the Toledo apartment of 88-year-old Velma McDowell, raped and strangled her with pantyhose, and stole $300 from her purse. Investigators found Williams's fingerprints, semen, and a pubic hair consistent with his identity at the crime scene, and DNA testing strongly matched him. After his arrest, Williams waived his Miranda rights and confessed during questioning, and later made unsolicited statements while blood and DNA samples were collected.

Procedural history

A Lucas County grand jury indicted Williams for aggravated felony murder with three death-penalty specifications, rape, aggravated burglary, and aggravated robbery. A jury found him guilty on all counts and specifications and recommended death; the trial court imposed death for aggravated murder and consecutive prison terms for the remaining offenses. Williams appealed directly to the Supreme Court of Ohio, which rejected all twenty propositions of law and affirmed the convictions and sentence.