State v. Williams
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The case revolves around Timothy Williams, who was 16 years old when he committed the offense in question. Williams rang the doorbell of Everett and Leslie Lawson's home, pretending to have been injured in a car accident. When Leslie opened the door to help, Williams shot her twice, killing her instantly. Williams was charged in juvenile court for conduct that would constitute murder and felonious assault if committed by an adult. The state did not charge Williams in the juvenile-court complaint for conduct that would constitute tampering with evidence.
The juvenile court found probable cause to believe that Williams committed all the offenses and transferred the case to the Hamilton County Court of Common Pleas. A grand jury then indicted Williams for murder, felonious assault, and tampering with evidence. Williams eventually pleaded guilty to involuntary manslaughter and tampering with evidence. He was sentenced to an aggregate 17-year prison term.
Williams appealed his tampering-with-evidence conviction to the First District, arguing that his statutory and constitutional rights were violated when he was indicted for and convicted of tampering with evidence, because that charge had not been transferred from the juvenile court to the adult court. The First District, relying on a previous decision, held that the adult court had lacked subject-matter jurisdiction over the tampering-with-evidence charge because the juvenile court had not found probable cause on that charge. The appellate court thus vacated Williams’s tampering-with-evidence conviction.
The state appealed to the Supreme Court of Ohio, which reaffirmed its previous holding that a defendant who was a juvenile when he committed an offense may be charged for and convicted of that offense in adult court even though a charge for the offense was not brought in juvenile court and considered in a bindover proceeding, if the charge is rooted in the same acts that were the subject of the juvenile complaint. Consequently, the Supreme Court of Ohio reversed the judgment of the First District Court of Appeals and remanded the matter to that court for it to resolve any remaining assignments of error.
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