State v. Williams

• Decision Date: 18 October 1995
• Docket Number: No. 24392,24392
• Citation: 468 S.E.2d 626,321 S.C. 327
• Parties: The STATE, Respondent, v. Luke A. WILLIAMS, III, Appellant. . Heard
• Court: South Carolina Supreme Court

Page 626

468 S.E.2d 626

321 S.C. 327

The STATE, Respondent, v. Luke A. WILLIAMS, III, Appellant.

No. 24392.

Supreme Court of South Carolina.

Heard Oct. 18, 1995.

Decided March 18, 1996.

Rehearing Denied April 18, 1996.

Daniel T. Stacey, Chief Attorney, South Carolina Office of Appellate Defense, Columbia, for Appellant.

Charles Molony Condon, Attorney General, John W. McIntosh, Deputy Attorney General, Donald J. Zelenka, Assistant Deputy Attorney General, Miller W. Shealy, Jr., Assistant Attorney General, Columbia; and Solicitor Donald V. Myers, Lexington, for Respondent.

BURNETT, Justice:

In this death penalty case, Appellant Luke A. Williams (Williams) was convicted of murdering his wife and twelve-year-old adopted son. We affirm.

FACTS

At approximately 11:00 a.m. on Wednesday, June 19, 1991, the bodies of Linda Williams (Wife) and Shawn Williams (Son) were discovered inside the family van in a forest in Edgefield County, South Carolina, approximately six miles from their home near Augusta, Georgia. The front bumper of the van was against a tree, and fire had partially damaged the vehicle. The investigators detected a strong odor of gasoline and found several metal cans containing gasoline inside the van. Wife was discovered in the driver's seat, which was positioned so far back that her feet could not reach the pedals, and Son was seated in the front passenger seat. Blood was found on a piece of PVC pipe on the van's floorboard. Wife was dressed in a gray t-shirt, gray sweatpants pulled down to her upper thigh, light pink socks, nylon panties, and she was not wearing a bra or shoes. Son was also shoeless and was wearing a t-shirt and sweatpants.

Wife suffered a black eye, a contusion on the bridge of her nose, contusions on her left forearm, and abrasions on her left shoulder. These injuries were consistent with having been caused by a human fist. The autopsy revealed that Wife's cause of death was blunt head trauma due to a beating. Son suffered a bruise to his forehead, as well as abrasions to his chin, back, and right side of his neck. His cause of death was asphyxiation due to manual strangulation. Wounds created by the fire were postmortem. Although the deaths occurred within the same time frame, a specific time of death was not determined.

At trial, several friends of Wife testified that she always dressed neatly and would not go out in public dressed in a t-shirt without a bra. Additionally, they stated that because Wife was short in stature, she always positioned the driver's seat of the van close to the steering wheel. One friend stated that she last spoke with Wife by telephone at 2:50 p.m. on June 18, 1991. A neighbor testified that on June 19, 1991, a car drove into the driveway at Williams' home between 1:00 and 2:00 a.m. Further testimony established that at approximately 7:00 a.m. on June 19, 1991, Wife's van was not parked in the driveway.

A bath towel and Son's tennis shoes with blood stains on them were found at Williams' home. In addition, Williams' right hand was severely bruised and swollen--this injury was consistent with having occurred on June Williams and Wife were experiencing significant marital and financial difficulties. Neighbors and friends stated that they frequently overheard Williams and Wife engaging in hostile arguments. One neighbor testified that she heard a "loud thump" during one of the arguments. In addition, Williams and Wife had declared bankruptcy, and foreclosure proceedings had been initiated against their home.

19th. Williams told a friend that on the day of the homicides, Wife and Son were planning to go shopping at Columbia Mall in Columbia, South Carolina. Prior to receiving the autopsy results, Williams informed the friend that Wife had been beaten to death, and Son had been strangled with a plastic wire wrap similar to wire wrap Son had in his bedroom. When asked if he killed Wife and Son, Williams did not respond.

Williams had substantially increased life insurance benefits on Wife and Son during May of 1991, designating himself as beneficiary. On May 7, 1991, Williams upgraded existing policies with Allstate Insurance Company to include auto related death benefits in the amounts of $100,000 for Wife and $20,000 for Son. Williams forged Wife's name on the enrollment form. After their deaths, Williams made claims under two Allstate policies in the amounts of $200,000 on Wife and $45,000 on Son. Williams also took out new life insurance policies for Wife and Son with State Farm Insurance Company effective May 30, 1991, providing Wife with death benefit insurance in the amount of $250,000 and Son with $25,000 in death benefit insurance. ¹ Williams indicated on the claims forms that Wife and Son had died in Edgefield County, South Carolina.

At the conclusion of the State's case, counsel for Williams moved for a directed verdict maintaining that there was insufficient evidence linking Williams to the murders, that venue in Edgefield County was not established, and that the circuit court lacked subject matter and personal jurisdiction. The motions were denied, after which Williams waived his right to testify and present a final argument. The jury found Williams guilty of murder. He was sentenced to death after the jury determined the existence of two statutory aggravating circumstances: (1) Williams committed the murders to receive money or a thing of monetary value; and (2) two or more persons were murdered.

DISCUSSION

I. Denial of the Motion for a Directed Verdict Based Upon

Lack of Evidence.

Williams contends the trial court erred in refusing to direct a verdict in his favor because the evidence failed to link him to the homicides. We disagree.

The trial court has a duty to submit the case to the jury where the evidence is circumstantial if there is any substantial evidence which reasonably tends to prove the guilt of the accused or from which his guilt may be fairly and logically deduced. State v. Williams, 303 S.C. 274, 400 S.E.2d 131 (1991); State v. Edwards, 298 S.C. 272, 379 S.E.2d 888 (1989). In ruling on a motion for a directed verdict, the trial judge is concerned with the existence of evidence, not with its weight. State v. Edwards, supra. When this Court reviews the denial of a motion for a directed verdict, it views the evidence in the light most favorable to the non-moving party, and if there is any direct or substantial circumstantial evidence which reasonably tends to prove the guilt of the accused, refusal by the trial judge to direct a verdict is not error. State v. Stokes, 299 S.C. 483, 386 S.E.2d 241 (1989); State v. Edwards, supra; State v. Irvin, 270 S.C. 539, 243 S.E.2d 195 (1978).

The record provides evidence from which Williams' guilt could fairly and logically be deduced: (1) Williams and Wife were having severe marital as well as financial difficulties; (2) Williams substantially increased life insurance benefits for Wife and Son during the month prior to the homicides and made himself the beneficiary, and the resulting death benefits would remedy Williams' poor financial situation; (3)

Williams forged Wife's name to insurance forms; (4) no motive for robbery was established, and it appeared from the way the victims were dressed and placed in the van that they had been forced from their home suddenly; (5) shortly after the homicides, Williams did not deny killing Wife and Son; (6) Williams knew details about the homicides prior to receiving results from the autopsy reports; (7) Williams' hand was injured and Wife's injuries were consistent with having been caused by a human fist; and (8) a towel and shoes were found at Williams' residence on which human blood was discovered. Accordingly, we conclude there was sufficient evidence to submit this matter to the jury.

II. Denial of the Motion for a Directed Verdict With Respect

to Venue and Jurisdiction.

Williams asserts he was entitled to a directed verdict because there was insufficient evidence to establish that the homicides occurred in Edgefield County, South Carolina. Therefore, he maintains that Edgefield County was without venue, and the circuit court lacked jurisdiction over him. We disagree.

A criminal defendant is entitled to a directed verdict when the State fails to present evidence that the offense was committed in the county alleged in the indictment. State v. Evans, 307 S.C. 477, 415 S.E.2d 816 (1992); State v. McCoy, 98 S.C. 133, 82 S.E. 280 (1914). For the purpose of establishing jurisdiction in a criminal prosecution, it is not necessary that the county in which the crime was committed be proved affirmatively if there is sufficient evidence from which it can be inferred. State v. McLeod, 303 S.C. 420, 401 S.E.2d 175 (1991); State v. Wharton, 263 S.C. 437, 211 S.E.2d 237 (1975); State v. Henderson, 285 S.C. 320, 329 S.E.2d 448 (Ct.App.1985). Moreover, venue, like jurisdiction, in a criminal case need not be affirmatively proved, and circumstantial evidence of venue, though slight, is sufficient to establish jurisdiction. State v. Owens, 293 S.C. 161, 359 S.E.2d 275 (1987); Wray v. State, 288 S.C. 474, 343 S.E.2d 617 (1986); State v. Wharton, supra. Generally, it can be inferred that the crime was committed in the state as well as county where the body is found. United States v. Rees, 193 F.Supp. 849 (D.Md.1961). Furthermore, where some acts material to the offense, and requisite to its consummation, occur in one county, and some in another, venue is proper in either county. State v. McLeod, supra; State v. Gasque, 241 S.C. 316, 128 S.E.2d 154 (1962).

Although there is evidence that some of the acts material to the homicides may have been committed in Georgia, the deaths occurred sometime between the time the victims were last seen in Georgia and the time the fire started in the van in South Carolina. Because both bodies were found in Edgefield County, we conclude there was sufficient evidence from which a trier of fact could reasonably...