Williams v. State

Summary

The Supreme Court of Georgia affirmed Qamar Williams’s convictions for malice murder and related firearms offenses arising from the shooting death of Calvin Chappell. The court held that Williams failed to satisfy the requirements for a new trial based on newly discovered evidence, that the trial court did not plainly err by declining to instruct the jury on involuntary intoxication, and that his ineffective-assistance claims failed for lack of demonstrated prejudice.

Holdings

1. The trial court did not abuse its discretion in denying Williams's motion for new trial based on newly discovered evidence because Williams failed to show both that the evidence could not have been discovered earlier through due diligence and that it was sufficiently material to probably produce a different verdict.
2. The trial court did not plainly err by refusing to instruct the jury on involuntary intoxication because the trial evidence did not show that Williams involuntarily consumed an intoxicating substance or lacked the mental capacity to distinguish right from wrong.
3. Williams failed to establish ineffective assistance based on counsel's failure to obtain surveillance footage from Club One Fifty-One and Waffle House because he did not demonstrate resulting prejudice.
4. Williams failed to establish ineffective assistance based on counsel's failure to call an expert concerning involuntary intoxication because he did not present or proffer evidence of what the expert would have said.
5. Williams was not entitled to relief based on cumulative prejudice because the record showed no prejudicial effect from any of counsel's alleged deficiencies.

Questions Presented

1. Whether newly discovered testimony that an unknown substance may have been placed in champagne consumed by Williams warranted a new trial.
2. Whether the trial court plainly erred by failing to instruct the jury on involuntary intoxication.
3. Whether trial counsel was ineffective for failing to obtain surveillance footage from Club One Fifty-One and Waffle House.
4. Whether trial counsel was ineffective for failing to present expert testimony concerning involuntary intoxication.
5. Whether the alleged deficiencies of counsel produced cumulative prejudice.

Disposition

affirmed