Georgia v. Williams
Annotate this CaseMichael Williams was indicted on two counts of felony murder, burglary in the first degree, aggravated assault, possession of a firearm during the commission of a felony, and possession of a firearm by a convicted felon. The State filed notice of its intent to introduce evidence of other wrongs, crimes, or acts pursuant to OCGA § 24-4-404 (b) (“Rule 404 (b)”). The State specified that the other-acts evidence would be offered as evidence of Williams’s motive and intent in killing Sandra Fields and would include Williams’s January 2017 arrest for family violence battery against another woman, Sommer Sheffield. After a hearing, the trial court ruled that evidence of the 2017 battery was inadmissible, on the basis that the probative value of the evidence was substantially outweighed by undue prejudice. The State appealed that ruling, contending the trial court misapplied the applicable balancing test and abused its discretion in excluding evidence of Williams’s prior act of domestic violence. The Georgia Supreme Court concurred with the State, vacated the trial court’s ruling and remanded for the trial court to reconsider the matter under the proper framework.
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