California v. WilliamsAnnotate this Case
Defendant Michael Williams stabbed his wife, victim Tanganyika Hoover Williams, twice in the neck, and she bled to death. The trial court permitted the State to introduce evidence at trial of defendant’s then 23-year-old Oklahoma conviction for shooting with intent to kill, and circumstances leading to that charge. Defendant’s jury found him guilty of first degree murder with personal use of a deadly weapon. The jury then found defendant sane, and the trial court found he had a prior serious felony conviction and prior strike (the Oklahoma conviction). The court sentenced defendant to prison for 50 years to life plus six years. Defendant claimed on appeal, in part, that the trial court abused its discretion when it permitted the State to introduce evidence underlying his Oklahoma conviction. The California Court of Appeal agreed this evidence had scant relevance to this case, and any relevance it did have was vastly outweighed by its potential for unfair prejudice. "This evidence was heavily relied on by the prosecutor in arguing for premeditation and deliberation in what was otherwise not a strong case for first degree murder, thus the error was prejudicial." However, because sufficient evidence (apart from the prior acts evidence) was presented in the case-in-chief to support first degree murder, the Court rejected defendant’s claims that trial counsel should have moved to acquit and that no substantial evidence supported the verdict. Therefore, a retrial on the first degree murder charge was not precluded.